Summary
In July 2024, the South Coast Air Quality Management District (AQMD) published its Preliminary Draft Rule Language along with its Draft Staff Report for Rule 1173 – Control of Volatile Organic Compound Leaks and Releases from Components at Petroleum Facilities and Chemical Plants. The proposed rule is more stringent than the current rule and will represent substantive changes for operators implementing Leak Detection and Repair (LDAR) programs at subject facilities. This article dives into the key changes that will affect facilities subject to this rule.
The draft rule language proposes four requirements to significantly reduce VOC emissions from components at petroleum facilities and chemical plants:
1. Lowering leak standards for components;
2. Lowering violation standards for components;
3. Adding Monthly Optical Gas Imaging (OGI) inspection of all components;
4. Reducing the component repair periods;
5. Updated Recordkeeping and Reporting Requirements
The proposed rule will go before the hearing board for approval is TBD, however, it is projected to go into effect by January 1, 2026.
Background
Rule 1173 was established to reduce and control volatile organic compound (VOC) leaks from piping components and pressure relief devices (PRDs) from refineries, chemical plants, marine terminals, oil and gas production fields, lubricating oil and grease re-refiners, natural gas processing plants and pipeline transfer stations. The rule is being amended in response to the Wilmington, Carson, West Long Beach (WCWLB) Community Emission Reductions Plan (CERP) and to implement the 2022 Air Quality Management Plan Control Measure FUG-01 which aims to reduce air pollution and improve public health in disproportionate communities from hazardous air pollutants. The AQMD governing board adopted the 2022 AQMP to achieve ozone attainment since U.S. EPA designated the Basin as “extreme” nonattainment in 2018. FUG-01, a control measure to reduce fugitive emissions from various industries, established enhanced Leak Detection and Repair (LDAR) such as OGI devices to include more rapid leak detection and responses, lowering allowable emissions from facilities.
Key Changes
To support the AQMD’s goal of reducing VOC emissions from piping components, other changes to the rule were made, in addition to the enhanced inspection and monitoring requirements. Key changes to the rule are summarized below:
1. Leak Standards
Leak standards define the threshold above which the facility needs to initiate component repair actions. Under the proposed rule, the leak thresholds have been reduced, in addition to incorporating a new component type. Table 1 below displays the difference.
Table 1 – Updated Component Leak Standards
Component Type | Old Leak Standard | New Leak Standard |
Compressor or Pump (Light Liquid) | 500 ppm | 400 ppm |
Pressure Relief Device (PRD) | 200 ppm | 200 ppm |
Pump (Heavy Liquid) | 100 ppm | 100 ppm |
Valve, Fitting, or other device (diaphragm, Hatch, sight-glass, meter) | 500 ppm | 100 ppm |
Fin Fan* |
| 100 ppm |
*Fin Fan is a new component that is listed in Proposed Amended Rule (PAR) 1173
2. Violation Standards
The violation standards define the leak threshold above which the facility is automatically in violation of the rule. Under the proposed rule, the violation standards will be reduced by 80% for light liquid and gas/vapor service components:
Table 2 – Updated Violation Standards
Component Type | Old Violation Standard | New Violation Standard |
Light liquid and gas/vapor service | 50,000 ppm | 10,000 ppm |
Heavy Liquid Service | 500 ppm | 500 ppm |
The rule currently allows for a 24-hour grace period to correct the leak after an AQMD inspection to avoid a violation. This provision will be removed; facilities will only have the opportunity to correct the leak the same day to avoid being cited for a violation of the rule.
3. Self-Inspection Requirements
The owner or operator will continue to be required to conduct Audio, Visual, and Olfactory (AVO) inspections for all accessible applicable components once per shift, however, inspections can be conducted once every 12 hours instead of the current requirement every 8 hours.
Additionally, operators will be required to conduct OGI inspections of all components at least once per calendar month unless a component will be out of service for more than 14 days of the calendar month due to turnarounds or outage.
Lastly, facilities will continue to conduct a Method 21 inspection quarterly for all accessible components, and annually of all inaccessible components, except for fin fans.
4. Repair Requirements
The proposed rule defines new repair requirements for visible emissions and visible leaks that are detected by owners/operators. For visible leaks and visible vapors from an accessible component, owners/operators have one day to fix/repair to eliminate the leak. If the owner/operator detects a visible leak from an inaccessible component, they have 12 hours to electronically or in writing to notify AQMD and have 14 days to eliminate the visible leak. For visible vapors detected from an inaccessible component, the owner/operator has 14 days to repair the visible vapor leak, and if the leak is not eliminated within 7 days, the owner/operator has to notify AQMD.
5. Recordkeeping and Reporting Requirements
All quarterly reports, records of leaks, visible leaks, visible vapors, repairs, and components awaiting repair will be submitted electronically to the Executive Officer in an “approved format” or in writing via Rule1173Reports@aqmd.gov if approved by the Executive Officer.
Conclusion
Rule 1173 is being updated to reduce VOC emissions from components from applicable facilities. In doing so, AQMD is establishing lower leak thresholds of applicable components, the requirement of using enhanced LDAR technologies, increased inspection frequencies, and shorter repair periods.