On September 23rd, 2024 the Sacramento-Metropolitan Air Quality Management District (SMAQMD) issued a Notice of Public Hearing regarding proposed Rule 490 which regulates the fugitive emissions of volatile organic compounds (VOCs) resulting from the bulk loading, transfer and dispensing of Liquefied Petroleum Gas (LPG). LPG is a common fuel consisting of propane, propylene, butane, and butylene with applications ranging from barbeques to automobiles to other industrial equipment. Proposed Rule 490 would require LPG bulk loading facilities and LPG transfer and dispensing facilities to install vapor recovery systems and low emission fixed level gauges that reduce fugitive emissions of VOCs. SMAQMD estimates the initial costs of retrofit required by facilities to comply with Proposed Rule 490 are $2.7 million dollars across roughly 10,000 units.
Background
LPG Transfer and Dispensing Facilities includes any facility that facilitates the transfer and storage of LPG from mobile fuelers or stationary tanks into containers for distribution. LPG bulk plants and transfer facilities load LPG received from storage terminals into stationary tanks. LPG is then transferred from the stationary tanks to bobtail trucks which deliver the fuel other facilities. LPG Bulk Loading Facilities are a subset of transfer facilities whose storage tanks have a water capacity of 10,000 gallons or more. Facilities utilize vapor recovery and equalization systems in order to maintain pressure between cargo and stationary tanks in a closed loop system. The transfer of LPG at bulk loading and transfer facilities results in fugitive VOC emission through entrapped liquids in supply lines, vapor and liquid leaks in transfer equipment, and through fixed liquid level gauges (FLLGs), or bleed valves, which act as safety devices on stationary tanks. FLLGs are valves with orifices which indicate the maximum fill level. Low emission FLLGs contain a greater number of orifices with smaller openings than standard FLLGs, allowing for a reduction in VOC emissions by 50%.
Sacramento County is located within the Sacramento Federal Nonattainment Area (SFNA), which is classified as “serious” ozone nonattainment for the 2015 National Ambient Air Quality Standards (NAAQS). If implemented, Rule 490 would help control ozone pollution by reducing VOC emissions from LPG bulk loading and transfer facilities. LPG facilities produce fugitive emissions of VOCs when they vent FLLGs. SMAQMD evaluated multiple methods of reducing fugitive VOC emissions and ultimately decided to follow the guidance of the South Coast Air Quality Management District (SCAQMD). SCAQMD found that industry professionals opted to install FLLGs in order to comply with similar proposed regulations. If adopted, the proposed rule would take effect if the contingency condition is triggered for either the 2008 or 2015 ozone NAAQS.
Proposed Rule 490 would apply to the transfer and dispensing of LPG from any bulk tank to another, including cargo tanks, stationary tanks, portable storage tanks, or cylinders. LPG containers specifically dedicated to recreational vehicles and transfers of LPG into containers with a water capacity less than four (4) gallons are exempt from the requirements of the proposed rule.
Vapor Recovery and Control Requirements
Effective one year after the adoption of the proposed rule, a LPG vapor recovery or equalization system, capable of recovering all LPG vapors, will be required at bulk LPG loading facilities. All vapor return lines must be properly connected to maintain a gas-tight environment and all equipment must be properly maintained. LPG transfer and dispensing facilities must install low emission connectors within one year of rule adoption.
LPG transfer and dispensing facilities (inclusive of bulk loading facilities) must meet one of the following conditions:
- Install low emission FLLGs; or
- Use a filling technology that monitors maximum fill level without the use of FLLG (i.e., monitors by weight).
If the first compliance method is chosen, all stationary storage tanks must be equipped with low emission FLLGs no later than 18 months of rule adoption. If a facility can demonstrate that the stationary tank cannot be retrofitted without tank relocation, the facility must equip the tank with a low emission FLLG within 48 months of rule adoption. Similarly, all cargo tanks and cylinders must be equipped with a low emission FLLG within 60 months and 18 months of the effective date of the rule, respectively.
If the second compliance method is chosen, the technology must be in place within one year of rule adoption.
Leak Detection and Repair Requirements
Effective one year after the effective date of Proposed Rule 490, LPG bulk loading and LPG transfer facilities must implement a leak detection and repair program. This program must include daily physical leak checks, bubble tests or EPA Method 21 inspections every 90 days, periodic employee training, leak tagging, and leak repair. The facility must keep records of the above items with a retention period of five years.
Submittals and Recordkeeping
Facilities subject to Proposed Rule 490 must submit an inventory of all low emission connectors installed at the facility, including connectors installed on owned or leased equipment associated with the transfer and storage of LPG beginning one calendar year after rule adoption. Initially, bulk loading facilities must submit an inventory that includes specific transfer equipment, manufacturer information, and lists all non-low emission connectors.
By July 1 of each subsequent year, bulk loading facilities must submit an end-of-year inventory including all containers equipped with low emission FLLGs. Container size, classifications, and number of installed low emission FLLGs must be included in this annual inventory submittal. The reporting requirements will end after five consecutive report submittals (60 months).
LPG bulk loading or transfer and dispensing facilities subject to the proposed rule will be required to maintain purchase and installation records of all low emission FLLGs and connectors. Facilities must also keep records of maintenance and leak activities, including maintenance records of the vapor recovery or equalization system. Records must be retained on site for a period of five years and annually submitted to SMAQMD by July 1st.
Key Timelines
LPG bulk loading facilities subject to Proposed Rule 490 must install and maintain a vapor recovery or equalization system within one calendar year of rule adoption. LPG transfer and dispensing systems must install low emission fixed liquid level gauges (FLLGs) on all containers associated with LPG transfer within 18 months of rule adoption or 48 months with written consent of the air district. All cargo tanks must be equipped with a low emission FLLG within 60 months. Bulk loading facilities must submit initial inventories of transfer components. Mobile fuelers must maintain maintenance logs of the vapor recovery and equalization system. All facilities must maintain purchase and installation records, maintenance and leak logs, and repair details for all applicable containers. Records must be submitted to SMAQMD by July 1st after the end of the first full calendar year of rule adoption and annual inventories on July 1st for each year after. The inventory submittal requirement ends after five consecutive submittals.
A public hearing is scheduled to occur on October 24th, 2024. If you would like to discuss the proposed adoption of this rule and how it may impact your facility, please contact Trinity’s Sacramento Office or call 916.444.6666.
