CA Rule 1178: Adding Technology to Fuel Tank Inspections to Reduce Emissions and Improve Air Quality

Upgraded District Rules Serving to Reduce Leaks in California

In 2024, South Coast Air Quality Management District (SCAQMD), which includes all of Orange County and the urban portions of Los Angeles, Riverside, and San Bernardino counties in the state of California, passed comprehensive updates to California Rule 1178 (CA 1178) to further reduce volatile organic compounds (VOC) emissions from organic liquid storage tanks at petroleum facilities within the district. The amended rule establishes more stringent leak detection, repair, and control requirements for storage tanks in gas refineries, bulk storage facilities, and oil production sites.

The amended rule is effective July 1, 2024.

Changes to CA 1178

The rule requires storage tank facility owners and/or operators to conduct more frequent leak detection surveying, specifically weekly optical gas imaging (OGI) surveying, at tank farms to ensure compliance with the updated regulation. The rule also requires facility owners and operators to provide more frequent and detailed reporting, conduct component inspections every six months, and repair any leaks detected through OGI within three days.

What does CA 1178 require?

CA 1178 establishes more stringent leak detection, repair, and control requirements for certain storage tanks used to store organic liquid that emit more than 40,000 pounds/20 tons of VOCs.

To comply with CA 1178, owners/operators of these storage tanks must conduct OGI monitoring that meets specific standards and at a certain cadence, depending on the type of storage facility. The person conducting this testing must complete specific training and maintain the camera/equipment used in testing in accordance with the manufacturer’s specifications and recommendations.

Who does it affect?

CA 1178 applies to floating- or domed-roof storage tanks located at petroleum facilities within the SCAQMD that have emitted more than 40,000 pounds (20 tons) of VOC in any reporting year since 2001.

Specifically, aboveground storage tanks with capacity equal to or greater than 75,000 liters (19,815 gallons) storing organic liquid, and storage tanks with a potential for VOC emissions of six tons per year used in crude oil and natural gas production operations.

What does this mean for storage tank owners and operators?

CA 1178 requires storage tank owners or operators to maintain tanks in conditions free of visible vapors caused by defective equipment. In other words, owners and operators are required to monitor more stringently for leaks, and when leaks are detected, remedy the issue.

To ensure equipment is effective and there are no leaks, owners and operators are required to conduct OGI leak detection inspections that meet certain requirements:

• The person conducting the inspection must be certified. To be certified, they must complete a manufacturer’s certification or training program for the OGI device used during the inspection. For more information, visit https://www.infraredtraining.com/en-US/home/training/ogi-courses/
• The OGI device must be maintained in accordance with the manufacturer’s specifications and recommendations.

Site owners/operators must also permanently identify all tanks subject to the upgraded inspection requirements via a visible sign that includes the tank number on the outside wall of the tank for inventory, inspection, and record-keeping purposes.

How to comply with the OGI requirements of CA 1178

To comply with the OGI components of the rule, storage tank owners/operators must have a certified person conduct OGI surveying at least once every calendar week. If a leak is detected, repairs must be made within three days.

Additionally, owners/operators must do the following, depending on the type of structure:

• External Floating Roof Tanks: a certified person must conduct an EPA Method 21 inspection or measure gaps of all roof openings on a semiannual basis and each time the tank is emptied and degassed. The certified person must also perform complete gap measurements of the Rim Seal System semiannually and whenever the tank is emptied and degassed. Furthermore, leaks equaling 500 parts-per-million must be recorded, requiring the use of Method 21 to ensure compliance.
• Domed External Floating Roof Tanks and Internal Floating Roof Tanks: a certified person must visually inspect the rim seal system and use an explosimeter to measure the lower explosive limit (LEL) semiannually; perform complete gap measurements of the Rim Seal System at least every 10 years and whenever the tank is emptied and degassed; perform complete gap measurements of all Roof Openings at least every 10 years and each time the tank is emptied and degassed.

How Can FLIR Help?

Owners, operators, and service providers can look to FLIR OGI cameras to help achieve compliance. FLIR OGI cameras feature the ability to not only detect fugitive gas emissions, but to quantitively measure the sizes of detected leaks, which is required for certain types of inspections. The new G-Series handheld OGI cameras or the QL320 companion device for detecting hydrocarbons can provide actionable, quantitative measurements of leaks escaping into the atmosphere on the respective devices.

Furthermore, FLIR also makes available certification courses to help customers learn to operate and make the most of their respective OGI investments, including online and in-person training in southern California and across the United States.