South Coast AQMD's Updated Rule 1178
Rule 1178 was established to further reduce VOC emissions from aboveground storage tanks located at petroleum facilities. It was updated in 2024 to implement Control Measure FUG-01 – Improved Leak Detection and Repair, a state regulatory measure aimed at reducing VOC emission at petroleum facilities by implementing advanced leak detection technologies. The rule utilizes advanced leak detection devices, which allows for faster identification and repair of leaks from equipment at applicable facilities that already have a leak detection and repair (LDAR) program.
Executive Summary
In September 2023, AQMD published their updated Rule 1178 – Further Reductions of Volatile Organic Compounds (VOC) from Storage Tanks at Petroleum Facilities. The rule applies to the following aboveground storage tanks located at petroleum facilities that emit more than 20 tons per year of VOC starting with emission inventory year 2000:
Aboveground storage tanks with a capacity of 19,815 gallons of organic liquid;
Storage tanks, used in crude oil and natural gas production operations, with a potential to emit more than 6 tons of VOC.
The rule was updated by establishing:
New inspection requirements, including the use of more advanced leak detection technologies such as Optical Gas Imaging (OGI) devices;
New reporting and recordkeeping requirements.
New requirements for tank doming.
This article addresses key updates to which facilities subject to Rule 1178 needed to be in compliance with as of July 2024.
Key Changes
1. OGI Inspections
The most significant update to Rule 1178 is AQMD’s requirement that facilities need to conduct weekly tank farm inspections and semi-annual component inspections using an OGI camera. While the prior rule did require quarterly OVA (Method 21 inspections), it did not require weekly inspections with an OGI.
Weekly tank farm inspections were implemented to ensure that all VOC leaks were detected and repaired as quickly as possible. According to SCAQMD, the number of tanks subject to Rule 1178 is a little bit over 1,000 in the South Coast basin. With the implementation of OGI inspections, SCAQMD expects that it will reduce VOC emissions by 0.82 tons per day.
Component inspections can be conducted in one of two different ways: one for the rim seal system and one from anywhere other than the rim seal system (i.e., floating roof tank components). Note that this new requirement to conduct a semi-annual component inspection with an OGI camera does not replace the already established semi-annual visual inspection or the existing quarterly inspections, therefore owners/operators may wish to conduct both the visual and OGI inspections simultaneously.
2. Reporting and Recordkeeping Requirements
With the inclusion of two different types of OGI inspections, there is a slight difference in reporting and recordkeeping requirements.
For weekly Tank Farm inspections, operators must utilize an OGI camera at ground level and inspect the tank. If visible vapors are not detected, the inspector can move on to the next tank. If however, visible vapors were detected and defects were visually detected in the tank, the owner/operator is required to notify AQMD within 24 hours and repairs need to be completed within 3 days. If visible vapors are detected, but the tank is not out of compliance (e.g., seals are intact with no signs of excessive gaps), the owners/operators should compare the video during subsequent tank farm inspections in the same calendar month. If the owners/operators determine that there is no change in size, density, flowrate of the visible vapors, then the tank is in compliance.
For semi-annual component inspections, the tank internals must be inspected via an OGI camera to determine if there are visible vapors or physical defects detected. Visible vapors or defects also require correction within three days of identification.
Owners/operators must keep a record of the weekly and semi-annual OGI inspections, including the OGI readings, and visual findings.
3. Doming External Floating Roof Tanks
While 1178 has historically required the doming of EFR tanks, the new rule update expands the definition of tanks and/or stored product required to be domed. Tanks required to be domed now include:
All External Floating Roof Tanks used to store Organic Liquid with a True Vapor Pressure of 3 psia or greater, except for tanks permitted to contain more than 97% by volume crude oil.
All External Floating Roof Tanks permitted to contain more than 97% by volume crude oil.
SCAQMD has disclosed a schedule for retrofitting applicable tanks based on the amount of crude storage and the number of tanks at the facility. The compliance schedule ranges from December 2030 to December 2041.
Conclusion
Beginning on July 1, 2024, the most significant Rule 1178 update since its inception became effective. Companies now have to implement new monitoring requirements including OGI inspections and must document compliance and report in accordance with new and nuanced rule provisions. ALG routinely assists clients, including LDAR contractors and facility operators, in keeping their environmental programs up to date.
Please contact Elliott Ripley at 805.764.6004 if you have any questions about compliance with Rule 1178.