South Coast Air Quality Management District to Update Rule 1173

South Coast Air Quality Management District (South Coast AQMD) in the last few months has held four working sessions to discuss proposed updates to Rule 1173 “Control of Volatile Organic Compound Leaks and Releases from Components at Petroleum Facilities and Chemical Plants.” If you work at a refinery, chemical plant, lubrication oil and re-grease refinery, marine terminal, oil and gas production field, natural gas processing field, or pipeline transfer station, these changes to Rule 1173 might affect your business operations.  

South Coast AQMD is committed to improving leak detection and Volatile Organic Compound (VOC) emissions per the Wilmington, Carson, West Long Beach (WCWLB) Community Emissions Reduction Plan (CERP) and the 2022 Air Quality Management Plan (AQMP) Control Measure FUG-01: Improved Leak Detection and Repair. The proposed Rule 1173 updates include requiring the use of enhanced leak detection technology at greater frequencies, establishing lower leak standards, and introducing contingency measures (CM) for applicable ozone National Ambient Air Quality Standards (NAAQS). 

The use of enhanced leak detection technology is part of the proposed self-inspection requirements update to Rule 1173, which includes a change from audio-visual inspections to Audio-Visual Olfactory (AVO) inspection methods and the addition of Optical Gas Imaging (OGI) inspections. Oil and gas production fields and pipeline transfer stations will need to conduct weekly AVO inspections of all accessible pumps, compressors, and atmospheric process relief devices (PRDs). Facilities to which this rule applies will need to conduct AVO inspections at least once per operating shift with less than 12 hours between inspections.    

Additionally, all facilities would conduct monthly OGI inspections of each component, unless a component will be out of service for more than 14 calendar days. These inspections would be done by someone who has completed a manufacturer’s certification or training program or an equivalent California Air Resources Board (CARB) training for an OGI device. Currently, OGI cameras on the market have an estimated lifetime of 10 years and a retail price of around $120,000. SCAQMD estimates an operating and maintenance cost of almost $5,000 per year per camera and a labor cost of about $400 per operating day. An inspection exemption for unsafe weather conditions is also proposed, allowing facilities to postpone inspections until conditions improve. 

The other major changes proposed involve leak and violation standards and repair requirements. The proposed rule lowers the violation standard for light liquid, gas, and vapor components from 50,000 ppm to 10,000 ppm. Reduced component leak standards are also proposed, lowering the standard for compressors and pumps (light liquid) from 500 ppm to 400 ppm and for valves, fittings, and other devices from 500 ppm to 100 ppm.  

Additionally, options for reporting and repairing leaks are proposed to be implemented in this rule. The proposal would require detected visible leaks and visible vapors from an accessible component to be eliminated no later than one calendar day after the detection. Visible leaks and visible vapors that are detected from an inaccessible component would be notified electronically to the Executive Officer before the end of the operating shift (less than 12 hours) and would be eliminated within 14 calendar days of the detection. Also, if a leak exceeds the leak standard for that component, the owner or operator would, within one day of detection, either use an OGI device to show no visible vapors are emitted or use an appropriate analyzer (Method 21) to confirm the leak is below the violation standards. In addition, they would complete repairs to meet the leak standards within 14 days of detection. 

The updates to this rule also incorporate ozone contingency measures (CM) if the United States Environmental Protection Agency (U.S. EPA) determines the South Coast Air Basin has not made reasonable further progress or attained the 2008 or 2015 ozone NAAQS by the required date. CM would go into effect in 60-day sequential stages after the determination is made public. Stage 1 CM, effective 60 days from the determination, would reduce leak standards for light liquid compressors or pumps to 300 ppm from the proposed 400 ppm. Stage 2 CM, effective after 120 days, would require the facility to conduct OGI inspections every two weeks, and Stage 3 CM, effective after 180 days, would reduce the leak standard for valves, fittings, and other devices to 50 ppm from 100 ppm. 

As with many of South Coast AQMD’s recent rule updates, the proposed Rule 1173 changes incorporate increases to record retention requirements from two to five years, as well as electronic records submission requirements. 

The proposed rule is scheduled to go before the South Coast AQMD Governing Board in a public hearing on October 4, 2024. The proposed changes may go into effect as early as October 1, 2025. 

ALL4 can assist you with evaluating the impacts of the proposed Rule 1173 changes on your facility, filing public comments, or even creating compliance calendars to help you stay on top of all your facility’s compliance obligations. If you have any questions regarding the proposed updates to Rule 1173 or ALL4’s strategy and compliance services, please reach out to your contact at ALL4 or Bruce Armbruster at barmbruster@all4inc.com or 909.477.7103.