On January 13, 2015, the Ventura County Air Pollution Control District (VCAPCD) adopted new Rule 74.33, Liquefied Petroleum Gas (LPG) Transfer or Dispensing. The new rule will help to reduce emissions of reactive organic compounds (ROC) from the transfer, dispensing, mobile fueling, and bulk loading of LPG. Expected to achieve ROC reductions of 104 tons per year, this new rule applies to any transfer of LPG to or from cargo tanks, stationary and portable storage tanks, and cylinders, excluding those on recreational vehicles. Operations affected by Rule 74.33 include forklift filling, retail sales, residential heating, vehicle filling, commercial operations, industrial operations, tank degassing operations, portable asphalt plants, LPG bulk plants and LPG storage, and dispensing facilities. However, LPG truck loading facilities subject to Rule 71.3 (Transfer of ROC Liquids) and Rule 74.10 (Components at Crude Oil and Natural Gas Production and Processing Facilities) are exempt from this rule. In addition, the proposed rule would not apply to the transfer of LPG into any container having a water capacity of less than four (4) gallons.
Effective July 1, 2015, ROC emissions from fugitive sources will be reduced through the requirement of Low-Emission Fixed Liquid Level Gauges (FLLG), also known as bleeder valves, and Low Emission Connectors. For LPG Bulk Loading Facilities, a vapor recovery or equalization system will be required to recover LPG vapors. This rule also establishes a Leak, Detection, and Repair (LDAR) program for LPG Bulk Plants and Storage and Transfer Facilities, which involves daily and monthly inspections using approved methods.
The new rule also establishes a series of record keeping and reporting requirements. Records of FLLGs and Low Emission Connectors installed must be kept for five years, along with the equipment specifications to show compliance with this rule. By July 1, 2017, all LPG bulk facilities must perform an inventory for 2016 of all Low Emission Connectors and mobile fuelers on site. This inventory will continue annually until 2020 and each inventory report is due on July 1 of the following year.
For more information regarding compliance with this rule, please contact Trinity at (949) 567-9880 or click here for more information.