On September 1, 2023, California’s South Coast Air Quality Management District (SCAQMD) Rule 1178 was amended to further reduce Volatile Organic Compound (VOC) emissions from storage tanks at petroleum facilities. While certain practices were previously established in the regulation, the most recent amendments added a new layer of complexity through OGI (Optical Gas Imaging) leak detection and screening processes for storage tanks at affected petroleum facilities. The new OGI requirements went into effect at the beginning of July 2024. The new amendments create differentiated methods for inspection and repair workflows. There are several key factors to consider when adjusting operations and records management practices to effectively adapt air compliance programs.
Who Does SCAQMD Rule 1178 Affect?
California owners or operators under SCAQMD governance with Storage Tanks for Organic Liquids located at any petroleum facility that emits more than 40,000 pounds per year of VOC, as reported in the Annual Emissions Report, are subject to the new OGI requirements. This includes:
- Aboveground storage tanks with a minimum capacity of 75,000 liters (19,815 gallons) or more that store organic liquids; and
- Crude oil and natural gas production operations storage tanks with a potential for VOC emissions of 6 tons per year.
SCAQMD Rule 1178 OGI Requirements
OGI Operator and Camera Requirements
OGI operators must complete a manufacturer certification or training program specifically designed for the OGI device used for inspections. This program is essential and cannot be substituted with internal OGI training or prior camera experience. Additionally, operators must adhere to the manufacturer's guidelines for operating and maintaining the OGI device to guarantee optimal performance and reliability. An OGI device is an infrared camera with a detector capable of visualizing gases in the 3.2-3.4 µm waveband.
Inspection Frequencies
Weekly tank farm inspections, conducted once per calendar week, are required for all affected storage tanks within a facility. These inspections involve a general screening of each tank, with a more in-depth component-level screening required if visible vapors are detected to identify the source. Semiannual component inspections, performed every six months, are mandated for all components in VOC service on each affected floating roof tank. These inspections involve a thorough inspection of all components.
Maintenance & Repair Requirements
SCAQMD Rule 1178 includes conditional factors that, if visible vapors are detected, require additional investigations, repairs, adjustments, or rim seal inspections. These actions must be completed within three days of detection, and the effectiveness of any repairs must be verified using the OGI camera. Rule 1178 does not include any Delay of Repair (DOR) provisions to extend repair deadlines.
Notification Requirement
The SCAQMD executive officer must be notified by telephone within 24 hours of inspection completion.
OGI Recordkeeping Requirements
Written records must be maintained for each inspection, including the tank identification, date of inspection, and inspection findings. The term "findings" refers to the identification of storage tanks with visible vapors and any subsequent repairs or determinations made. Additionally, 5-second OGI videos of any visible vapors must be retained. Records must be preserved and accessible upon request by the executive officer for a period of five years. Detailed information regarding OGI requirements can be found in Rule 1178 Sections (f)(4), (g), and (h).
Strategies for SCAQMD Rule 1178 Compliance
To successfully implement the new OGI requirements and comply with the SCAQMD Rule 1178 amendments, facilities must carefully consider strategies for capturing the additional data and meeting the strict timelines. This involves adapting existing data management systems, establishing clear procedures for leak detection and repair, and leveraging technology to automate processes and streamline workflows. Consider the following strategies:
Find methods to distinguish between tank farms and individual tanks in your data management system.
By establishing 'vantage points' as distinct inspection entities, with a weekly regulation attached, facilities can meet the tank farm inspection requirement without interfering with other inspections. Additionally, creating individual inspection records for each tank with a semi-annual regulation and tracking system will capture the essential OGI screening requirements. This differentiation allows technicians to identify conditional factors and associate relevant data with specific tanks when emissions are detected.
Adhere to strict timeframes for review & repair and have contingency plans for resolution.
Facilities should anticipate that the detection of visible vapors will often necessitate rapid action to notify stakeholders, mobilize personnel for repairs, and confirm completion within the specified three-day timeframe. To be prepared, it is important to develop contingency plans for the availability of key personnel, including during potential holiday periods. Additionally, teams should have timely access to inspection results and a centralized database to efficiently capture and share leak updates across the organization.
Automate notification & workflow infrastructure for relevant personnel & key stakeholders.
Stakeholders must be notified of visible emissions immediately and/or within 24 hours. To streamline this process and improve workflows, consider automating notifications and repair progress updates for personnel. Implementing cloud-based record management, API connections to work order systems, and quick-access reports can enhance efficiency. Additionally, ensure that notifications are customized to align with the specific responsibilities of individual personnel and their assigned locations. This includes customization for environmental vs. operations staff and associating tanks and personnel with specific process units or facilities.
Centralize records and find a solution for quick reporting.
The rule mandates the retention of recorded inspections, image files, and relevant video files of detected visible emissions for a period of five years. To create a central location for records and findings, consider attaching OGI video and image files to the relevant inspection or leak in a database.
Determine reliability and flexibility of use.
For effective compliance, evaluate the reliability and flexibility of your data management system in handling the complexities of multiple regulations and varying deadlines. A system that effectively tracks critical compliance requirements and deadlines can help teams operate more efficiently.
The SCAQMD Rule 1178 amendments add complexity to compliance efforts. Evaluating how technology can assist with management and tracking can help ensure compliance. While low-cost workarounds may be effective for some, certain circumstances may necessitate re-evaluating records management options.
Trihydro's air quality specialists and technology consulting team are well-versed in evolving regulations and can provide your organization with the support needed to maintain compliant operations and reporting. If you're seeking assistance with understanding or implementing Rule 1178 or utilizing Leaktracker Pro to help with the record-keeping and compliance requirements, please don't hesitate to contact us.
