SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

FINAL STAFF REPORT FOR 

PROPOSED AMENDED RULE 1173 – CONTROL OF VOLATILE ORGANIC 

COMPOUND LEAKS AND RELEASES FROM 

COMPONENTS AT PETROLEUM FACILITIES 

AND CHEMICAL PLANTS 

Dated: May 15, 2007 

Deputy Executive Officer 

Planning, Rule Development, and Area Sources 

Elaine Chang, DrPH 

Assistant Deputy Executive Officer 

Planning, Rule Development, and Area Sources 

Laki Tisopulos, Ph.D., P.E. 

Planning and Rules Manager 

Planning, Rule Development, and Area Sources 

Larry M. Bowen, P.E. 

Authors: Kennard Ellis Air Quality Specialist 

Reviewed by: Ed Muehlbacher, P.E. Program Supervisor 

John Olvera Senior Deputy District Counsel 

Contributors: Roger Christopher Supervising Air Quality Inspector 

Martha Thomas Air Quality Inspector 

 Helen Chin Air Quality Inspector 
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

GOVERNING BOARD 

Chairman: WILLIAM A. BURKE, Ed.D. 

 Speaker of the Assembly Appointee 

Vice Chairman: S. ROY WILSON, Ed.D. 

 Supervisor, Fourth District 

 Riverside County Representative 

MEMBERS:

MICHAEL D. ANTONOVICH 

Supervisor, Fifth District 

Los Angeles County Representative 

BILL CAMPBELL 

Supervisor, Third District

Orange County Representative 

JANE W. CARNEY 

Senate Rules Committee Appointee 

RONALD O. LOVERIDGE 

Mayor, City of Riverside 

Cities Representative, Riverside County 

GARY OVITT 

Supervisor, Fourth District 

San Bernardino County Representative 

JAN PERRY 

Councilmember, 9th District 

Cities Representative, Los Angeles County, Western Region 

MIGUEL PULIDO 

Mayor, City of Santa Ana 

Cities Representative, Orange County 

TONIA REYES URANGA 

Councilmember, City of Long Beach 

Cities Representative, Los Angeles County, Eastern Region 

Vacant 

Governor’s Appointee 

DENNIS YATES Mayor, City of Chino 

Cities Representative, San Bernardino County 

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env. 
TABLE OF CONTENTS 

EXECUTIVE SUMMARY -------------------------------------------------------------------------------- 1 

CHAPTER 1 - BACKGROUND ----------------------------------------------------------------------- 1-1 

CHAPTER 2 – EMISSION INVENTORY ------------------------------------------------------------ 2-1 

A. VOC Emissions from Components 

B. Emission Inventory for Atmospheric Pressure Relief Devices (PRDs) 

CHAPTER 3 - CONTROL TECHNOLOGY ASSESSMENT ------------------------------------- 3-1 

A. Electronic Valve Monitoring Devices for Atmospheric PRDs 

B. Implementing Leak Detection and Repair (LDAR) Program 

CHAPTER 4– PROPOSED AMENDMENTS -------------------------------------------------------- 4-1 

CHAPTER 5 - EMISSION IMPACTS ----------------------------------------------------------------- 5-1 

A. LDAR Program for Lubricating Oil and Grease Re-Refiner 

B. Require Electronic Monitoring Devices for Atmospheric Process PRDs 

CHAPTER 6 – COST AND COST EFFECTIVENESS --------------------------------------------- 6-1 

A. LDAR Program 

B. Electronic Monitoring Devices for Atmospheric Process PRDs 

C Parameter Monitoring for all Atmospheric Process PRDs or Telltale Indicators if 

not Feasible 

CHAPTER 7 – DRAFT FINDINGS -------------------------------------------------------------------- 7-1 

CHAPTER 8 – CALIFORNIA ENVIRONMENTAL QUALITY ACT --------------------------- 8-1 

CHAPTER 9 – SOCIO-ECONOMIC ANALYSIS --------------------------------------------------- 9-1 

CHAPTER 10 – COMMENTS AND RESPONSES ------------------------------------------------ 10-1 

APPENDIX A – COMPARATIVE ANALYSIS ----------------------------------------------------- A-1 
EXECUTIVE SUMMARY 

Proposed Amended Rule 1173 ES-1 May 15, 2007 

Rule 1173 reduces volatile organic compound (VOC) leaks from the following for components 

in light liquid/gas/vapor and heavy liquid service: valves, fittings, pumps, compressors, pressure 

relief devices (PRDs), diaphragms, hatches, sight-glasses and meters. Facilities subject to the 

rule are refineries, chemical plants, oil and gas production fields, natural gas processing plants, 

and pipeline transfer stations. This proposed amendment adds facilities engaged in the blending, 

compounding and re-refining of lubricating oils and greases and marine terminals to further 

reduce VOC leaks. In addition, Rule 1173 also requires facilities subject to the rule to notify the 

AQMD of PRD releases and requires monitoring of atmospheric PRDs installed on process 

equipment. The proposed amendment seeks to improve and strengthen monitoring requirements 

applicable to atmospheric PRDs. 

After the December 2002 amendment, the AQMD established a PRD release notification 

program. As a result of several releases in the first year of the notification program, staff has 

investigated the causes of the releases to determine if rule amendments were appropriate for 

further control of PRD releases. For releases that were each in excess of five hundred pounds, 

the AQMD received notifications for eight in 2003, three in 2004, none in 2005 and four in 2006. 

Although staff will continue to monitor the situation, amendments to further regulate VOC 

releases is not recommended at this time. However, during the investigation, staff discovered 

that technology has developed for more effective monitoring and recording the magnitude and 

duration of releases in a cost effective manner. Therefore, staff is proposing amendments to 

require improved monitoring of all atmospheric PRDs. In addition, other parts of the rule are 

being clarified. 

The following are highlights of the proposed amendments: 

• Require marine terminals and facilities that re-refine lubricating oils and greases and 

marine terminals to implement aleak detection and repair (LDAR) programs. 

• Require petroleum facilities refineries to install electronic monitoring devices on their 

atmospheric process PRDs to improve monitoring and quantification of future potential 

releases. 

• Require refineries, marine terminals and lubricating oil and grease re-refiners to submit a 

new or revised compliance plan, identifying the atmospheric process PRD inventory and 

the monitoring method option selected. 

• Require lubricating oil and grease re-refiners to notify the AQMD of any atmospheric 

PRD releases exceeding the reportable quantity limits as stipulated in 40 CFR, Part 117, 

Part 302 and Part 355 including any atmospheric releases exceeding 100 pounds of VOC. 

• Clarify that quarterly monitoring reports are required for all atmospheric process PRDs. 

The emission reductions associated with the implementation of heavy and light liquid LDAR 

program at lubricating oils and grease re-refiners and marine terminals are estimated to be 0.4 

tons per day VOC based on the 2003 AQMP inventory. 

The cost effectiveness of the proposed amendments for heavy liquid and light liquid components 

LDAR was calculated at $919 per ton of VOC reduced. 
EXECUTIVE SUMMARY 

Proposed Amended Rule 1173 ES-2 May 15, 2007 

VOC emissions from PRD releases for 2003 through 2006 have ranged from 89 to 0.04 tons per 

year. Although an emission reduction has not been quantified for the improved monitoring, it is 

expected that the improved monitoring will ultimately result in reduced VOC emissions from 

PRD leaks and fewer PRD releases. The cost for the proposed improved monitoring ranges from 

$3.3 million to $6.6 million based on the type of monitoring device and installation and the cost 

of the data retrieval system selected by each refinery. 
CHAPTER 1 - BACKGROUND 

Proposed Amended Rule 1173 1-1 May 15, 2007 

BACKGROUND 

Rule 1173 was originally adopted on July 7, 1989 and subsequently amended on several 

occasions. The original intent of the rule was to control fugitive VOC leaks from light liquid/gas 

valves, fittings, pumps, compressors, PRDs, hatches, meters, diaphragms, and sight-glasses at 

refineries, chemical plants, oil and gas production sites, natural gas processing plants, and 

pipeline transfer stations. Subsequently, the rule was amended to control fugitive VOC 

emissions from components in heavy liquid service. 

The most recent amendment on December 2, 2002, required monitoring and reporting of releases 

from atmospheric process PRDs, and control of PRDs that release significant amounts of VOCs 

or payment of a mitigation fee. The mitigation fees paid to the AQMD are to be used for air 

quality improvement projects in the area impacted by the release. This amendment also required 

facilities to control fugitive VOC leaks from heavy liquid components. 

The December 2002 rule required refineries to produce a PRD inventory and enhance monitoring 

by either equipping 20 percent of their atmospheric PRDs with tamper-proof electronic 

monitoring devices by the next turnaround starting in 2004, or use electronic process control 

instrumentation by July 2004. One refinery chose to install electronic monitors and all the others 

chose to monitor process parameters (temperature and/or pressure) or utilize telltale indicators 

where process monitoring was infeasible. The rule also requires that specific action be taken for 

releases in excess of specific amounts. For all releases greater than 500 pounds of VOCs, the 

refinery has to perform a failure analysis within 30 days of each release. Also, in the event of a 

second release in excess of 500 pounds of VOCs from the same equipment within any five year 

period or any one release that exceeds 2,000 pounds of VOC from a process unit requires that the 

company connect all PRDs from that unit to vapor recovery or control equipment. The rule also 

has a provision which allows the refinery to elect to pay $350,000 for each release in lieu of 

connecting to vapor recovery or control, provided the refinery notifies the AQMD within 90 days 

of the date of the release. 

The Resolution of the Governing Board adopting PAR 1173 (December 6, 2002) directed staff to 

provide periodic updates on PRD releases to appropriate Board Committees. On April 23, 2004, 

staff provided the Stationary Source Committee with a summary of the atmospheric PRD releases 

from process equipment to date and indicated that based on the reported releases in 2003 there were 

five releases which had exceeded 2,000 pounds. Two of these releases occurred at the BP West 

Coast Products refinery in Carson and another three occurred at the Equilon Enterprises (Shell Oil 

Company) refinery in Wilmington. Board members expressed concerns about the frequency and 

amount of emissions from PRDs (i.e. about 89 tons of VOCs in 2003). They indicated that staff 

should analyze the data gathered to decide whether or not further amendments to Rule 1173 should 

be recommended. One of the concerns expressed was that during the rule development and hearing 

in 2002, the refineries stated that large VOC releases from atmospheric PRDs were extremely rare. 

However, if the releases in 2003 were an indication of normal activity, perhaps other options for 

controlling emissions from atmospheric PRDs should be considered. 

Since the end of 2002, there have been nine atmospheric PRD releases that emitted between 500 and 

2,000 pounds and eight releases greater than 2,000 pounds VOC, including one release that was 

categorized as exempt due to a Southern California Edison power outage. The total amount of VOCs 

released from atmospheric process PRDs have decreased from 2003 to 2005. Releases 
CHAPTER 1 - BACKGROUND 

Proposed Amended Rule 1173 1-2 May 15, 2007 

ranged from 89 tons in 2003, 4 tons in 2004 to less than 0.5 ton in 2005. However, these releases 

continued to be random with an increase in PRD releases reported in 2006. One refinery had four 

releases ranging from 713 pounds to over 11,000 pounds for a total of slightly more than 7.5 tons 

during 2006. It should be noted that in some cases refineries have taken actions to minimize 

potential PRD releases in the future by voluntarily connecting PRDs to vapor recovery systems, as 

well as implementing operational procedures. 

Staff has evaluated the data from atmospheric PRD releases and emissions reported to the AQMD 

from 2003 through 2006 and concluded that amendments to require further control of atmospheric 

PRDs are not necessary at this time. However, staff has determined that PRD monitoring can be 

significantly enhanced by taking advantage of recent advancements in the wireless electronic 

monitoring technology and decided to proceed with a rulemaking process to amend Rule 1173 to 

require enhanced PRD monitoring on all atmospheric process PRDs. Staff will continue to monitor 

PRD release activity and recommend additional control if the situation changes. 

Recent advances in wireless electronic monitoring are significant. Wireless monitors will enable 

real-time monitoring of atmospheric PRDs and can be used anywhere within a facility. Currently, 

there are facilities that have atmospheric PRDs which are equipped with telltale indicators consisting 

of “socks” and similar type devices. With wireless monitors in place, a facility operator will be able 

to continuously monitor PRDs, accurately measure pressure and the time span for releases and 

thereby allowing for effective quantification of releases. In addition, this data can be incorporated 

into a facility’s existing data collection system without much added cost. 

The costs associated with installing, maintaining, troubleshooting and upgrading wiring have 

escalated while the costs of wireless technology have continued to drop, particularly in areas of 

installation and maintenance. Installation costs of wiring could range from $50 to $100 per foot, 

including labor. Also, as wires age, they can crack or fail. It should also be noted that 

inspecting, testing, troubleshooting, repairing and replacing wires require time, labor and 

materials. With wireless systems an operator will be able to eliminate the cost associated with 

the abovementioned activities in addition to costs associated with downtime and production 

stoppage. Based on information collected from manufacturers and distributors, the capital, 

operational and maintenance costs associated with wireless monitors are relatively low. 

Wireless monitors have been proven to be intrinsically safe and they also allow facility operators 

greater flexibility in the placement of monitors. This advantage over wired systems is 

particularly significant due to the fact that mobile equipment such as cranes are positioned at 

different locations of a facility during maintenance, turnarounds and other downtime activities at 

a refinery. 

While there may be great emphasis placed on the capital and maintenance costs associated with 

wireless systems, it should also be noted that with improved monitoring comes the benefit of 

being aware of when a release occurs. This allows the operator to repair leaks in a timely 

manner and reduce lost product with which there is a cost-saving factor associated. 

The facilities presently subject to this rule include refineries, chemical plants, oil and gas 

production sites, natural gas processing plants, and pipeline transfer stations. The proposed 

amendments will also require facilities engaged in blending, compounding and re-refining 
CHAPTER 1 - BACKGROUND 

Proposed Amended Rule 1173 1-3 May 15, 2007 

lubricating oils and greases, as well as marine terminals that handle organic liquids to implement 

a LDAR program and will require enhanced monitoring of any atmospheric process PRDs that 

may be present. These facilities are classified under Standard Industrial Code (SIC) 2992 – 

Lubricating Oils and Grease Re-Refining facility that operates distillation equipment, heaters and 

storage tanks. Staff has determined that the operation of these equipment and the associated 

components, such as pumps, valves and connectors has a potential for gaseous and liquid VOC 

leaks and potential emissions are no different than that of other petroleum operations and 

chemical plants regulated by Rule 1173. Staff’s analysis identified one facility, Demenno 

Kerdoon, located in Compton, California, as a facility that should also be regulated under this 

proposed amendment to Rule 1173. 

A total of twelve marine terminals that are operated by ten companies have been identified as 

well. These facilities are classified under Standard Industrial Codes (SIC) 4226 and 5171 – A 

Facility, Equipment or Structure constructed to handle the loading or unloading of organic liquid 

in or out of marine tank vessels. Staff has also determined that the operations carried out at 

marine terminals and the associated components have the potential to leak fugitive emissions as 

well. 
CHAPTER 2 – EMISSION INVENTORY 

Proposed Amended Rule 1173 2-1 May 15, 2007 

EMISSION INVENTORY 

The emission inventory is comprised of fugitive VOC emissions from components and from 

process atmospheric PRD releases. The proposed amendments will require lubricating oil and 

grease re-refiners and marine terminals operations to implement the LDAR program as 

prescribed under Rule 1173. Although an estimated inventory can be developed for PRD 

releases, it is difficult to estimate an emission reduction from an enhanced PRD monitoring 

program. Therefore, staff will only analyze the additional VOC emissions and emission 

reductions from the additional proposed source categories (re-refiners and marine terminals) to 

be regulated under Rule 1173 and those from PRD releases. There will be no emissions or 

inventory estimates associated with the enhanced PRD monitoring provisions of the proposal. 

Table 2.1 

New Sources added to Rule 1173 

Oil and Gas Re-Refiner AQMD ID# 

Demenno Kerdoon 800037 

Marine Terminal AQMD ID# 

BP West Coast Terminal 1 132137 

BP West Coast Terminal 2 800052 

Valero Refining (Ultramar) 800198 

Equilon (Shell) LLC 117560 

Equilon (Shell) Long Beach 117319 

ExxonMobil 800092 

ConocoPhillips 111642 

Westway 110924 

General Petroleum 108417 

Vopak 800040 

Amerigas 111896 

Jankovich 1971 

A. VOC Emissions from Components 

The emission inventory for fugitive VOC emissions from components was established based on 

reported emissions by the lubricating oil and grease re-refiner and marine terminals in the Rule 

1173 universe for the fiscal year 2003-2004 and the 2003 AQMP. Currently, as part of the AER 
CHAPTER 2 – EMISSION INVENTORY 

Proposed Amended Rule 1173 2-2 May 15, 2007 

program, facilities are required to report fugitive VOC emissions for specific component 

categories such as components in light liquid/gas/vapor (light liquid) service and fugitive VOC 

emissions from pumps and valves in heavy liquid service. Fugitive VOC emissions from other 

components not explicitly listed in the AER such as connectors, hatches, sight glasses and 

meters) are to be reported under the “other” category. 

Table 2.2 

2003-04 Reported Emissions 

Component Inventory 2003-2004 

Emissions TPY 

Heavy Liquid Valves 3,041 6.64 

Heavy Liquid Pumps 120 24.16 

Heavy Liquid Connectors 1,828 7.08 

Other Components in 

Heavy Liquid 5,107 18.40 

Light Liquid Valves 3,712 125.45 

Light Liquid Pumps 98 25.04 

Light Liquid Connectors 2,409 7.30 

Other Components in Light 

Liquid Service 7,193 18.4 

Total 23,508 232.47 

After review of annual emissions reported by marine terminals, staff has determined that these 

emissions appear to be based on emission factors associated with a LDAR program as required 

by the current rule. While the use of lower emission factors may be appropriate for those 

facilities that are voluntarily implementing a LDAR program as specified in Rule 1173, even 

though they are not subject to this requirement, it is not appropriate for most other facilities that 

are not fully implementing the program. Therefore, staff has elected to estimate annual 

emissions by using AQMD default factors until the reported emission reductions can be verified. 

B. Emission Inventory from Process Atmospheric PRDs 

Releases from atmospheric PRDs occur randomly and therefore, an accurate inventory of 

emissions from this source category can only be approximated. Table 2.3 - Atmospheric PRD 

Inventory lists the number of atmospheric PRDs installed on process equipment at refineries. 
CHAPTER 2 – EMISSION INVENTORY 

Proposed Amended Rule 1173 2-3 May 15, 2007 

Table 2.3 

Atmospheric PRD Inventory 

Facility No. of Atmospheric Process PRDs (1) 

In Gas/Vapor Service In Liquid Service 

BP West Coast Products 387 205 

Chevron 49 (2) 0 

ConocoPhillips, Carson 15 0 

ConocoPhillips, Wilmington 8 0 

Edgington 14 0 

ExxonMobil 35 0 

Lundy Thagard 9 0 

Equilon (Shell Oil) 40 0 

Valero 8 0 

TOTAL 565 205 

 (1): Reported by refineries in 2005 

 (2): 9 of 49 PRDs have been equipped with electronic valve monitoring devices; one more will be added at next turnaround 

Since 2003, Rule 1173 requires refineries and chemical plants to report releases from PRDs to 

the AQMD within 30 days of the event. Table 2.4 is a summary of atmospheric PRD releases 

from process equipment for the calendar years 2003 through 2006. The data is presented in a 

format to coincide with reporting and action requirements of the rule. Rule 1173 requires 

refineries with over 20,000 barrels per day crude oil throughput to connect all PRDs serving that 

equipment to a vapor recovery or control system following a second release from the same PRD 

within five years and exceeding 500 pounds of VOC or after any release exceeding 2,000 pounds 

of VOC. In lieu of connecting the PRD to control, a refinery may pay a mitigation fee of 

$350,000. Table 2.4 also delineates PRD release data for major processing units, such as the 

crude distillation unit, coker unit and fluid catalytic cracking unit; staff believes these process 

units to have the greatest potential to experience atmospheric PRD releases. 
CHAPTER 2 – EMISSION INVENTORY 

Proposed Amended Rule 1173 2-4 May 15, 2007 

Table 2.4 

Summary of Process Atmospheric PRD Releases from 2003 - 2006 

PRD 

Release 

Year 

Process Unit 

No. of 

Releases 

<500 lbs 

VOC 

Emissions 

(lbs) 

No. of 

Releases 

500 - 

2,000 lbs 

VOC 

Emissions 

(lbs) 

No. of 

Releases 

>2,000 

lbs 

VOC 

Emissions 

(lbs) 

Total 

VOC 

Emissions 

(lbs) 

2003 FCCU 0 0 2 3,096 4 158,834 

Crude 

Distillation 0 0 1 1,475 2 14,612 

Other 3 415 0 0 0 0 

 Total 3 415 3 4,571 6 173,446 178,432 

2004 FCCU 1 4 0 0 0 0 

Coker 1 65 1 553 1 6,004 

Super 

Fractionator 1 306 1 923 0 0 

Other 4 399 0 0 0 0 

Total 7 774 2 1,476 1 6,004 8,254 

2005 FCCU 1 30 0 0 0 0 

Other 13 768 0 0 0 0 

Total 14 798 0 0 0 0 798 

2006 Debutanizer 0 0 1 1,668 0 0 

Reformer 

Depropanizer 0 0 0 0 1 11,564 

Reformer 

Suction 

Drum 

0 0 1 713 0 0 

Reformer 

Flash Drum 0 0 1 1,051 0 0 

Other 2 338 0 0 0 0 

Total 2 338 3 3,432 1 11,564 15,334 

The data in Table 2.4 shows PRD releases in 2003 of more than 89 tons of VOC; reducing 

significantly to approximately 4 tons and 0.4 tons for years 2004 and 2005, respectively; 2006 

saw an increase in PRD releases to a total of slightly more than 7.5 tons of VOC. Table 2.5 lists 

the significant PRD releases since the beginning of 2003 and the compliance options taken by 

the refineries. There were no reported significant PRD releases in 2005. 
CHAPTER 2 – EMISSION INVENTORY 

Proposed Amended Rule 1173 2-5 May 15, 2007 

Table 2.5 

Summary of Process Atmospheric PRD Releases 

Greater Than 500 Pounds VOC Year 2003 - 2006

PRD 

Release 

Date 

Refinery Process Unit 

VOC 

Emissions 

>500 – 2,000 

lbs 

VOC 

Emissions 

>2,000 lbs 

Comments 

1/12/03 ExxonMobil Crude Tower 9,965 Exempt – SCE Power 

Outage 

2/18/03 Equilon FCCU 

Fractionator 1,697 1st Release > 500 lbs 

3/19/03 BP FCCU 

Dehexanizer 1,399 1st Release > 500 lbs 

3/21/03 BP FCCU 

Debutanizer 122,293 Mitigation Fee - $350,000 

5/3/03 Equilon FCCU 

Fractionator 11,854 Mitigation Fee - $350,000 (2nd release from same unit) 

7/23/03 Conoco 

Phillips 

Secondary Crude 

Column 1,475 1st Release > 500 lbs 

10/18/03 Equilon FCCU 

Fractionator 21,591 Mitigation Fee - $350,000 (3rd release from same unit) 

11/2/03 BP Crude Tower 4,647 Connect to Control 

12/15/03 Equilon FCCU 

Fractionator 3,096 Mitigation Fee - $350,000 

(4th release same unit) 

1/18/04 BP Coker Area DEA 553 1st Release > 500 lbs 

9/28/04 BP Super 

Fractionator 923 1st Release > 500 lbs 

11/23/04 BP Coker 

Debutanizer 6,004 Connect to Vapor Recover System 

2/19/06 BP #3 Debutanizer 1,668 1st Release > 500 lbs 

3/6/06 BP 

#2 Reformer 

LPG Compressor 

Suction Drum 

713 1st Release > 500 lbs 

7/21/06 BP #3 Reformer 

Flash Drum 1,051 1st Release > 500 lbs 

12/5/06 BP 

#2 Reformer 

Straight Run 

Depropanizer 

 11,564 Mitigation Fee - $350,000 
CHAPTER 3 – CONTROL TECHNOLOGY ASSESSMENT 

Proposed Amended Rule 1173 3-1 May 15, 2007 

CONTROL TECHNOLOGY ASSESSMENT 

In this chapter, control techniques for reducing fugitive emissions from atmospheric PRDs and 

components are described. A relatively new wireless technology that is used specifically to 

continuously monitor atmospheric PRDs will be discussed at length. In addition, the 

implementation of the LDAR program and modification and replacement of existing components 

will also be discussed. 

A. ELECTRONIC VALVE MONITORING DEVICES FOR ATMOSPHERIC PRDs 

PRDs are designed to relieve pressure and provide safe operations. They typically function by 

opening at a given set pressure, venting and then resealing when a safe pressure has been reestablished. In addition to the environmental concern resulting from emissions releases, any 

consistent leak through a PRD represents a loss of valuable process gas. 

Without continuous monitoring and diagnostic instrumentation, PRDs are normally placed on a 

preventative maintenance schedule with inspections being done on scheduled intervals based on 

operating history. This practice results in repair of valves that may not be broken and a cost 

associated with such maintenance. 

Wireless Instrument technology was chosen by one refinery based on the fact that operators were 

given the option in the 2002 amendment of the rule to install tamper-proof electronic valve 

monitoring devices on 20 percent of their atmospheric PRDs. The 20 percent strategy was 

chosen to allow the technology to be tested and further developed over a period of time for this 

particular industrial application. 

Wireless Instrument Network Integration to Existing Plant Systems

First Generation: 

The initial form of wireless systems for industry has mostly used cellular phone style radio links, 

using point-to-point or point-to-multipoint transmission. The Wireless Instrumentation products 

contain a radio transmission link that connects the wireless instrument field unit (acoustic or 

pressure) to a base radio. This link is designed to serve in industrial applications for reliable 

transmission and receipt of sensor data. 

The wireless field monitoring unit relays the status of valves back to a central base-radio where 

the emergency station location is tagged and identified. The base radios are designed to 

accommodate a networked installation, with each base radio defining a wireless cell and each 

wireless instrument field unit becoming a node in that cell. The size of each cell is determined 

by the effective transmission distance of the radio link between the base-radio and the various 

wireless instruments. 

Depending on the brand of monitoring equipment each base radio may monitor up to 50 or more 

valves. The network can be expanded to a total of as many as 16 base radios covering various 

operating units and providing the capability to continuously monitor up to 800 points. 
CHAPTER 3 – CONTROL TECHNOLOGY ASSESSMENT 

Proposed Amended Rule 1173 3-2 May 15, 2007 

Second Generation (Mesh Network System): 

Mesh Network is a new technology in which devices assist each other in transmitting packets 

through the network, especially in adverse conditions and where there are obstructions. The 

mesh network system is a point-to-point-to-point system. A node can send and receive 

messages, as well as function as a router capable of relaying messages for its neighbors. A mesh 

network offers multiple redundant communication paths throughout the network. If one link 

fails for any reason, the network automatically routes messages through alternate paths and 

hence eliminates possible line of sight obstacles.

A wireless mesh network system may require an extensive survey of the facility site in order to 

determine the proper positioning of the sensor units. One mesh technology wireless 

manufacturer has set July 1, 2007 for its first production shipment, while another has installed 

more than 20 units at a local refinery (atmospheric PRDs) and is in the process of testing them. 

It should also be noted that first generation wireless systems can be integrated into second 

generation wireless systems and there should be no significant added costs in incorporating a 

point-to-point system into a mesh network system. 

Components of Wireless Pressure Relief Device Monitoring System Technology

New (wireless) technology allows continuous monitoring of PRDs without significant capital 

expense and makes it easy for operators to identify valve leaks, even if they discharge into a 

common exhaust or flare header. VOCs that are emitted from PRDs may be accurately 

identified, estimated, remedied and reported immediately, thereby removing the need for 

unnecessary preventative maintenance procedures and emission releases. 

Acoustic (Sensor) Field Unit 

Recently, technology has been introduced that enables continuous monitoring of PRDs using 

sensors that can communicate through a wireless radio link to a central data collection point. 

The new self-contained Monitoring Field Unit includes an acoustic sensor element and a 

transceiver providing two-way communications and operating in the 900 MHz band with battery 

life that could be as long as five years depending on the manufacturer. During normal operations, 

a PRD remains closed until a specified amount of pressure builds up within the system. Once the 

pressure exceeds a certain safety limit, the PRD opens until pressure drops below the safety 

limit. During the time that the valve is open ultrasound is generated. The Acoustic Field Unit 

can effectively measure the duration of the overpressure event. If a PRD is leaking ultrasound 

will be generated and rise in proportion to the flow rate and pressure 

The non-invasive installation of an acoustic sensor coupled with wireless transmission of data on 

the PRD operation provides an easy and inexpensive monitoring solution when compared to 

hard-wired systems. Also, built into the system is a Frequency-Hopping Spread System (FHSS) 

which is a frequency modulation process that eliminates unauthorized interception. 

Typically, an industrial environment is noisy by nature and noise activity can be continuous or 

intermittent. However, noise activity that is created by valve leakage can be distinguished by 

employing filters of ultrasonic magnitude and duration. 
CHAPTER 3 – CONTROL TECHNOLOGY ASSESSMENT 

Proposed Amended Rule 1173 3-3 May 15, 2007 

The acoustic unit is fairly maintenance free and is operated on a “C” size lithium battery that has 

a life of up to five years and remaining battery life may be one of the outputs from this unit for 

some manufacturers. The unit contains extensive self-checking software and hardware that 

continuously monitors the operation. Any sensor or device parameter that is out of specification 

is identified and reported. 

Pressure (Sensor) Field Unit 

Wireless pressure sensors can be applied either on the inlet (upstream) or outlet (downstream) of 

a PRD. The pressure field unit is available in gauge pressure or absolute pressure versions. 

Each is self-powered and contains a pressure sensor, signal conditioning circuitry and an RF 

(radio frequency) transceiver that operates in a certain waveband that is normally license-free. 

Data from the sensor is transmitted to the Base Radio for centralized monitoring and data 

acquisition. Most manufacturers have distinct models that are designed to operate within certain 

ranges of pressure. The field units can be used for conditions as low as 30 psig to 5,000 psig 

based on manufacturer’s information provided. 

The advantages of using pressure sensors over acoustic sensors include the positive verification 

of actual system pressure and the elimination of the need to filter background noise from the 

monitoring data. Wireless pressure sensing also provides positive indication of release events as 

well as time stamps and duration. However, the downside of pressure sensing is its inability to 

detect leakage effectively. This problem is most likely to exist in situations where flow rates are 

very high and turbulence occurs and it is common to have high ambient levels of ultrasound. 

Differential Pressure (Sensor) Field Unit 

This unit is equipped with an integrated differential pressure sensor, signal conditioning circuitry 

and an RF (radio frequency) transceiver. Data from the sensor is transmitted to the base radio for 

centralized monitoring and data acquisition. 

Base Radio 

The Base Radio is at the heart of the wireless technology solution. It communicates with all of 

the deployed Field Units and interfaces with the existing control system. One base radio can 

communicate with as many as 50 field units. Multiple based radios can be used to accommodate 

larger installations. The base radio comes in an explosion-proof and weatherproof housing. 

Depending on the layout of a facility which will determine whether there is clear line of sight or 

not, the range of field units may be between 500 feet and 3,000 feet. 

Electronic valve monitoring devices are designed for pressure relief valve monitoring. The 

devices provide information about overpressure events and detect potentially unsafe or 

undesirable pressure relief valve conditions. The device calculates flow through the valve and 

records the date, time and event duration. The data can be retrieved from the device, at any time, 

with PC software. 
CHAPTER 3 – CONTROL TECHNOLOGY ASSESSMENT 

Proposed Amended Rule 1173 3-4 May 15, 2007 

B. IMPLEMENTING A LEAK DETECTION AND REPAIR (LDAR) PROGRAM 

Rule 1173 requires petroleum related facilities and chemical plants to implement a LDAR 

program to reduce fugitive VOC releases. The LDAR program is best suited to pumps, valves 

and connectors where repairs of these components could result in potentially significant VOC 

emission reductions. Facilities that are included in this amendment of Rule 1173 will be subject 

to an LDAR program which is outlined in the rule and is defined by the following: (1) 

component identification; (2) leak thresholds; (3) inspection frequencies and (4) repair 

frequencies. 

The facility operator is required to visibly and clearly identify all major components for the 

purpose of recording repairs, replacements and re-inspections. In the event that there are 

changes in major component identification the operator must seek the approval of the Executive 

Officer. 

The rule amendment defines leak limits based on either an instantaneous standard or a 

continuous 24-hour standard. 

Inspections are a critical component of the LDAR program and consist of two types. Audiovisual inspections involve direct physical observation to gather qualitative information, while 

quantitative inspections involve a direct measurement of components by use of an analyzer using 

EPA Method 21. 

All accessible pumps, compressors and atmospheric PRDs are required to be audio-visually 

inspected once during every 8-hour operating period. The operator must also conduct EPA 

Method 21 quarterly inspections of all accessible components in light liquid/gas/vapor service 

and pumps in heavy liquid service, while all inaccessible components in light liquid/gas/vapor 

service require EPA Method 21 inspections annually. Provided an operator successfully 

operates and maintains all accessible components at a facility for five consecutive quarters based 

on a schedule that is outlined in the rule language, he/she may request for a change in inspection 

frequency from quarterly to annual. If a facility has more than 25,000 components the operator 

is required to simultaneously record all component inspections in an electronic format. 

Time periods for component repairs depend on the type of leak and may vary from one day to 

seven days from the time a leak is detected according to a repair schedule outlined in the rule 

language. After a component has been repaired, the operator must conduct an inspection within 

one to 30 calendar days depending on the component and service type. In the case of an 

atmospheric PRD release an inspection must be done within one calendar day of repair and a reinspection within 14 calendar days. Components found to be subjected to five or more repairs 

within a 12-month period must be replaced or vented to an air pollution control device upon 

approval by the Executive Officer. 
CHAPTER 4 – RULE PROPOSAL 

Proposed Amended Rule 1173 4-1 May 15, 2007 

RULE PROPOSAL 

Proposed Amended Rule (PAR) 1173 will add two new facility groups that were not included in 

the rule when it was last amended in December 2002. The current version of Rule 1173 

addresses control of VOC leaks and releases from components at petroleum facilities and 

chemical plants. PAR 1173 will require a LDAR program to reduce leaks and releases from 

components at lubricating oil and grease re-refineries which are engaged in blending, 

compounding and re-refining lubricating oils and greases from purchased mineral, animal and 

vegetable materials, as defined in Standard Industrial Classification Code (SIC) 2992; petroleum 

refineries engaged in the production of lubricating oils and greases are classified in Standard 

Industrial Classification Code 2911, and therefore are not included in this definition. PAR 1173 

will also require a LDAR program to reduce fugitive releases from components at marine 

terminals that handle organic liquids. Both lubricating oil and grease re-refineries and marine 

terminals must be in compliance with Rule 1173 identification requirements by September 30, 

2007, and in compliance with all other requirements starting January 1, 2008.

Definitions of Lubricating Oil and Grease Re-Refiner, Marine Terminal have been added and the 

definition of Facility has been amended to include these two new source categories. While SIC 

code 5171 specifically addresses distribution activities at petroleum bulk stations and terminals, 

SIC code 4226 represents a number of different types of storage activities. Among these 

activities represented under SIC 4226 is storage that is limited to strictly petroleum bulk stations 

and terminals. 

Among the issues addressed in the previous amendment of Rule 1173 was the monitoring of 

VOC releases from atmospheric process PRDs at petroleum refineries. The operator was 

provided with three options that would allow the operator to monitor the PRD and estimate the 

duration of any releases. One option required PRDs to be monitored by use of electronic process 

control instrumentation to monitor certain process parameters such as temperature and pressure. 

In cases where operators did not have the capability of electronic process control, they were 

allowed to use telltale indicators to detect when a release occurred although this option does not 

allow for very accurate quantification of VOC releases. The third option required that twenty 

percent of the atmospheric process PRDs be equipped with tamper-proof electronic monitoring 

devices. 

Since the last rule amendment, electronic valve monitoring technology has improved and a larger 

number of companies have become involved in the manufacturing and distribution of wireless 

equipment that can be used for atmospheric PRD monitoring. With that development and the 

low cost and ease of installation staff has determined that all atmospheric PRDs should be 

equipped with electronic monitoring devices unless it can be demonstrated to the satisfaction of 

the Executive Officer that installation of this type of monitor is not feasible for a specific PRD. 

In that case, process monitoring or telltale indicators would be required. However, situations 

where tamper-proof electronic monitoring device cannot be used are few, if any. 

For a refinery with less than 50 atmospheric process PRDs, an operator will be required to install 

tamper-proof electronic monitoring devices on a minimum of 50 percent of all atmospheric 

process PRDs by January 1, 2009. By July 1, 2009, the remaining atmospheric PRDs serving 

process equipment will have to be equipped with tamper-proof electronic monitoring devices. 
CHAPTER 4 – RULE PROPOSAL 

Proposed Amended Rule 1173 4-2 May 15, 2007 

Refineries that have more than 50 atmospheric PRDs must install tamper-proof electronic 

monitoring devices on a minimum of 20 percent of all atmospheric PRDs serving process 

equipment by January 1, 2009. By July 1, 2009 a minimum of 40 percent of all atmospheric 

PRDs must be equipped with tamper-proof electronic monitoring devices. All remaining 

atmospheric PRDs serving process equipment must have electronic monitoring devices installed 

by July 1, 2010. 

The number of atmospheric PRDs that an operator will be required to install with tamper-proof 

electronic monitoring devices by each deadline date outlined in PAR 1173 will be based on a 

baseline PRD inventory that is established in the plan that is required to be submitted to the 

AQMD by December 31, 2007. Staff recognizes that some facilities have significantly more 

atmospheric process PRDs than other refineries and has taken this factor into consideration by 

creating a schedule that allows these refineries more time than refineries with a smaller number 

of atmospheric process PRDs. In addition, due to the relatively inexpensive price of this 

monitoring technology and the fact that it has been proven to be successful for this application, 

the time allowed to meet the PRD deadlines are reasonable and the overall cost is not expected to 

be prohibitive. 

During the period of time prior to refineries installing tamper-proof electronic monitoring on all 

atmospheric process PRDs, operators will be required to continue monitoring these PRDs with 

the existing electronic process control instrumentation that allows for real time continuous 

parameter monitoring or telltale indicators. 

Petroleum facilities that can demonstrate to the satisfaction of the Executive Officer that 

installation of tamper-proof electronic valve monitoring devices on process unit PRD(s) by the 

specified dates would be infeasible or constitute a safety hazard may be allowed to delay 

installation of these devices on the PRD(s) until no later than the next scheduled turnaround of 

that process unit after the adoption of this rule amendment. 

PAR 1173 requires that all petroleum facilities install and operate tamper-proof electronic 

monitoring devices that are capable of measuring the duration of each PRD release and 

quantifying the amount of VOC released from each atmospheric process PRD. However, if a 

refinery chooses to adopt an alternative approach that includes the use of process parameter 

monitoring or telltale indicator, the operator will be required to install a tamper-proof electronic 

monitoring device at the PRD release point (on the process unit) that is capable of accurately 

measuring the release duration and use continuous process parameter monitoring to quantify the 

VOC release. In cases where an operator does not have a process parameter in place, there must 

be a telltale indicator. Under these situations the quantification of the release will be dependent 

on data provided by the electronic monitor. The use of any such alternative approach will 

require that the operator demonstrate on or before the compliance dates in subparagraphs 

(h)(1)(A) and (h)(1)(B), to the satisfaction of the Executive Officer, that continuous parameter 

monitoring of the process unit accurately represents the actual process conditions at the location 

of the PRD release to the atmosphere. 

In the future, if a refinery decides to direct all the gases and vapors released from atmospheric 

PRD(s) to VOC vapor recovery or control system, the operator will not be required to install and 

operate electronic PRD monitors for those PRD(s), provided the operator submits a revised 

compliance plan no later than December 31, 2008. The compliance plan must clearly identify 
CHAPTER 4 – RULE PROPOSAL 

Proposed Amended Rule 1173 4-3 May 15, 2007 

the PRDs to be connected and also include a schedule for connection. Staff has determined that 

this is sufficient time to complete plans and make decisions associated with these projects. 

Refineries will be required to complete projects related to directing these PRDs to VOC vapor 

recovery or control systems by no later the next turnaround after December 31, 2008. However, 

prior to the completion of the connection to vapor recovery or flare, operators will still be 

required to monitor these atmospheric PRDs by using electronic process control instrumentation 

that allows for real time continuous parameter monitoring or telltale indicators as required by the 

rule. 

A refinery will not be required to install tamper-proof electronic valve monitoring devices on 

atmospheric PRDs that release to drains and are subject to the requirements of Rule 1176, if the 

operator can demonstrate to the satisfaction of the Executive Officer that all released material 

meets the definition of heavy liquid. By definition, heavy liquids contain less than 10 percent 

VOC by volume at 150 degrees C (by test methods outlined in PAR 1173). VOC emissions 

associated with these releases are not expected to be significant. However, atmospheric PRDs in 

liquid service that release to grade have the potential to release greater amounts of VOC 

emissions compared to PRD releases that are confined to drains due to the fact that upon release 

these liquids spread, thereby creating a larger surface area for evaporation. Therefore, a refinery 

will be required to install tamper-proof electronic valve monitoring on all atmospheric PRDs that 

release to grade. 

In order to provide the AQMD with a comprehensive status update on its atmospheric PRDs, 

operators at all facilities subject to Rule 1173 must submit a revised compliance plan by 

December 31, 2007. This update must include a process atmospheric PRD inventory, pressure 

set point, size, location and the option selected for PRD monitoring. 

Lubricating oil and grease re-refiner and marine terminal operations are considerably different 

from the types of processes conducted at refineries. In general, the liquids processed by 

lubricating oil and grease re-refiners tend to be heavier and less volatile, while marine terminals 

are predominantly involved in transporting of fluids via pipeline systems. Although some fluids 

at marine terminals are heated to assist in moving them, the fluid temperatures at marine 

terminals are significantly less than those at refineries. Therefore, lubricating oil and grease rerefiners and marine terminals will be required to monitor all process atmospheric PRDs using 

electronic process control instrumentation that allows for real time process parameter monitoring 

starting January 1, 2009. Where process parameter monitoring is not feasible, telltale indicators 

may be used instead. However, the deadline for installing telltale indicators is December 31, 

2007. 

Lubricating oil and grease re-refiners and marine terminals will be required to notify the 

Executive Officer within one hour of release followed by a written report within 30 days for all 

process atmospheric PRD releases in excess of 100 pounds of VOC or in excess of reportable 

quantity limits as stipulated in 40 CFR, Part 117 (Determination of Reportable Quantities for 

Hazardous Substances) Subchapter D – Water Program, Part 302 (Designation, Reportable 

Quantities and Notification) and Part 355 (Emergency Planning and Notification) Subchapter J – 

Superfund, Emergency Planning and Community Right to Know. The written report following 

the release must include information such PRD type, size and location; the cause, date, time and 

duration of each release, in addition to corrective actions taken to prevent a subsequent release. 
CHAPTER 4 – RULE PROPOSAL 

Proposed Amended Rule 1173 4-4 May 15, 2007 

By December 31, 2007, an operator will be required to submit a compliance plan that contains 

the process atmospheric PRD inventory, pressure set point, size, location and the option selected 

for monitoring. Monitoring of process atmospheric PRDs is to commence no later than January 

1, 2009. 

It should also be noted that the process PRD requirements of the rule were not intended to 

regulate VOC releases from PRDs that are located on cooling water systems. Although industry 

argues that VOC leaks from these sources are small, staff intends to monitor and make future 

observations to determine if PRD VOC releases from the process side of the exchangers are 

significant enough to be addressed in a future cooling water rule if needed. 

All operators of facilities included in this rule amendment are required to submit quarterly 

electronic reports for all process atmospheric PRDs indicating the process parameter(s) 

monitored as a function of time. These reports are required to be submitted no later than 30 days 

after the end of each calendar quarter. 
CHAPTER 5 – EMISSION IMPACTS 

Proposed Amended Rule 1173 5-1 May 15, 2007 

EMISSION IMPACTS 

A. LDAR PROGRAM FOR LUBRICATING OIL AND GREASE RE-REFINERS 

Currently, there is no rule requirement in place for an inspection and maintenance program for 

components in heavy and light liquid service at lubricating oil and grease re-refiners and marine 

terminals. Including these components in a LDAR program can reduce these VOC emissions at 

this source category. As of January 1, 2007, one lubricating oil and grease re-refiner, Demenno 

Kerdoon, has initiated implementation of a LDAR program as required under Rule 1173 as part 

of a settlement agreement in June 2006 with the AQMD. 

In order to establish the emission impacts of the rule, it is necessary to calculate the emission 

reductions associated with a LDAR program. Per AQMD Rule 301, affected facilities are 

required to report all fugitive emissions in the Annual Emission Report on forms R3, T1 or P1. 

To report emissions from all components not subject to a LDAR program, default emission 

factors are used. 

Three marine terminals have already implemented a LDAR program at their facilities; the 

proposed amendments will not result in any additional VOC emission reductions or 

implementation costs for these marine terminals. The other nine marine terminals, based on the 

2003-2004 AER reports they have submitted to the AQMD, indicated they have implemented a 

limited or screening-type LDAR program. For these nine facilities, staff will use the VOC 

emissions reported to the AQMD as the baseline emissions to determine additional VOC 

emission reductions that will be a result of the required LDAR program under the proposed 

amendments to Rule 1173. 

Where an LDAR program is in place and monitoring of components takes place, the following 

methods may be used to calculate emissions: 

• The Correlation Equation and Factor Method, or 

• The Screening Value Range Method. 

These methods were developed based on data in the 1995 EPA Protocol and 1997 CAPCOA 

Review, and apply to components that are subject to the inspection and maintenance program of 

Rule 1173. (Guidelines for Fugitive Emissions Calculations – Petroleum Industry, SCAQMD, 

June 1999). 

During an inspection required by current Rule 1173, the leak rate from a component would be 

measured and recorded using a calibrated organic vapor analyzer, according to EPA Reference 

Method 21. This measured value is called a screening value, and will be used in the following 

equations based on the Correlation Equation and Factor Method to determine fugitive emission 

inventories for the types of components listed below. 

The current rule requires a LDAR program for pumps in heavy liquid service and a leak 

threshold of 100 ppm for all components in heavy liquid service, including valves and 

connectors. Based on data from refineries implementing an LDAR program for heavy and light 
CHAPTER 5 – EMISSION IMPACTS 

Proposed Amended Rule 1173 5-2 May 15, 2007 

liquid components, it is assumed that pumps in heavy liquid service will average 25 ppm after 

the LDAR program and that valves and connectors will average 50 ppm, or half the leak 

threshold; light liquid and gas/vapor phase components will average 5,000 ppm, or half the leak 

threshold. 

LDAR Emission Calculations for Components in Heavy and Light Liquid Service for 

Refineries and Marine Terminals (per Table IV-3a; CAPCOA-Revised 1995 Correlation 

Equations and Factors)

Valves: 

Fugitive emissions (TPY) = 5 x 10 (-6) x 24 x 365 x (Screening Value) 0.747

Pumps: 

Fugitive emissions (TPY) = 1.12 x 10 (-4) x 24 x 365 x (Screening Value) 0.622

Connectors: 

Fugitive emissions (TPY) = 3.37 x 10 (-6) x 24 x 365 x (Screening Value) 0.736

Other Components: 

Fugitive emissions (TPY) =1.92 x 10 (-5) x 24 x 365 x (Screening Value) 0.642 

SAMPLE CALCULATIONS

Projected emissions from valves in heavy liquid service at 50 ppm average, calculated with the 

valve correlation equation, are: 

Emissions valves = 3,041 x [5 x 10-6 x (50)0.747] lb/hr x 24 hrs/day x 365 days/yr /2000 lb/ton 

= 1.24 TPY (See Column 3 of Table 5.1) 

Projected emissions from pumps in heavy liquid service at 25 ppm average, calculated with the 

pump correlation equation, are: 

Emissions pumps = 120 x [1.12 x 10-4 x (25)0.622 ] lb/hr x 24 hr/day x 365 days/yr / 2000 lb/ton 

= 0.44 TPY 

Projected emissions from connectors in heavy liquid service at 50 ppm average, calculated with 

the connector correlation equation, are: 

Emissions conn. = 1,828 x [3.37 x 10-6 x (50)0.736] lb/hr x 24 hrs/day x 365 days/yr / 2000 lb/ton 

= 0.48 TPY 
CHAPTER 5 – EMISSION IMPACTS 

Proposed Amended Rule 1173 5-3 May 15, 2007 

Projected emissions from other components in heavy liquid service at 50 ppm average, 

calculated with the correlation equation used for other components are: 

Emissions other = 5,107 x [1.92 x 10-5 x (50)0.642] lb/hr x 24 hrs/day x 365 days/yr/ 2000 lb/ton 

= 5.29 TPY 

Table 5.1 

Estimated Emission Reductions 

Component Inventory 

2003-2004 

Emissions 

TPY 

Emissions 

after LDAR 

TPY 

Emissions 

Reduction 

TPY 

Heavy Liquid 

Valves 3041 6.64 1.24 5.40 

Heavy Liquid 

Pumps 120 24.16 0.44 23.72 

Heavy Liquid 

Connectors1,2 1,828 7.08 0.48 6.60 

Heavy Liquid 

(Others) 5,107 18.40 5.29 13.11 

Light Liquid 

Valves 3,712 125.45 47.12 78.33 

Light Liquid 

Pumps 98 25.04 9.61 15.43 

Light Liquid 

Connectors1,2 2,409 7.3 18.76 (0)3

Light Liquid 

(Others) 7,193 18.4 143.36 (0)3

Total 23,508 232.47 226.30 142.59 

1. The number of connectors is assumed to be 25 % of components (connectors, sight-glasses, meters and hatches) reported in the other category of AQMD AER form R3. The remaining components were placed in to the “Others” category 

2. When not reported, the ratio of connectors in heavy liquid to light liquid service was estimated based on the ratio of valves in 

 heavy liquid to light liquid service. In cases where enough information was not provided, components in heavy liquid and 

 light liquid were divided evenly 

3. Emissions reported were found to be less than the computed LDAR emissions and zero default will be used until the 

 calculation methods used by the marine terminals are verified 

Staff is aware that a few impacted facilities are voluntarily implementing a LDAR program and, 

therefore, a portion of the estimated emission reductions may have already been realized. 

Although PAR 1173 would make these reductions enforceable, staff intends to work with 

impacted facilities to verify the scope of the LDAR program being implemented voluntarily, and 

to the extent warranted, adjust the emission reduction estimated and cost analysis accordingly. 
CHAPTER 5 – EMISSION IMPACTS 

Proposed Amended Rule 1173 5-4 May 15, 2007 

B. REQUIRE ELECTRONIC MONITORING DEVICES FOR ATMOSPHERIC 

PROCESS PRDs 

Electronic monitoring devices will greatly improve the identification and quantification 

of releases from atmospheric process PRDs; these devices do not directly reduce PRD 

releases or emissions. However, staff believes that improved monitoring will ultimately 

result in reduced PRD leaks and fewer PRD releases. No direct emission reduction is 

claimed for this requirement. 
CHAPTER 6 – COST AND COST EFFECTIVENESS 

Proposed Amended Rule 1173 6-1 May 15, 2007 

COST AND COST EFFECTIVENESS 

This chapter will present the cost calculations related to PAR 1173. In the case of the LDAR 

program for lubricating oil and grease re-refiners and marine terminals, there are associated cost 

effectiveness calculations. However, in the case of atmospheric process PRDs, releases are 

episodic and random in nature, but are quantifiable. Potential VOC emission releases from 

PRDs will be subject to improved continuous monitoring, but these emission releases are not 

reduced by specific control equipment. Therefore, cost effectiveness calculations will not be 

applied to electronic monitoring. 

The cost effectiveness of the proposed changes and associated calculations and assumptions used 

to derive it are shown in the following sections. Cost effectiveness is expressed as the ratio 

between the present value of the total cost of implementing a proposed control measure and the 

benefit of installing that control measure, which in this case is the emission reduction. 

A. LDAR PROGRAM 

The rule amendment will add one lubricating oil and grease re-refining facility (Demenno 

Kerdoon) and twelve marine terminals to the list of facilities whose operations and equipment 

category qualify them to be subject to the requirements of this rule. The component inventory 

for these facilities is shown in Table 6.1 - Cost Effectiveness for a LDAR Program. 

On January 1, 2007, Demenno Kerdoon initiated the implementation of a LDAR program as 

required under Rule 1173 as part of a settlement agreement met in June 2006 with the AQMD. 

The following analysis demonstrates the cost effectiveness to implement an LDAR program. 

Three of the twelve marine terminals that are included in the Rule 1173 program are already in 

compliance with the requirements of the rule and therefore staff has been determined that there 

will be no additional cost associated with these facilities. 

In order to calculate the cost effectiveness of the LDAR program, the present value of the capital 

cost and operating cost during the useful life of the program must be calculated using the 

following formula: 

PV = C + A x PVF, where: 

PV = Present Value of the control equipment 

C = Capital costs associated with implementing the LDAR program 

A = Annual costs incurred to administer the LDAR program, such as inspection 

 and component repair 

PVF = Present Value Factor, which is 8.11 for an assumed 10 years equipment life and 

4% rate of inflation. 
CHAPTER 6 – COST AND COST EFFECTIVENESS 

Proposed Amended Rule 1173 6-2 May 15, 2007 

The following assumptions are made in order to calculate the present value for the LDAR 

program of components in heavy and light liquid service: 

- Quarterly inspection frequency for components 

- Emission reductions for pumps are based on an average emission of 25 ppm based on 

data from a refinery that has a LDAR program. 

- Emission reductions for valves and connectors are based on an average emission of 50 

ppm base on AQMD staff field survey. 

- All cost information from AQMD Rule 1173 Staff Report (December 2002) was indexed 

upward to 2006 cost by applying a factor of 18 percent to account for inflation (Marshall 

Swift Equipment Cost Index – Year 2002 = 1,104.2 and Year 2006 = 1,302.3) 

- Inspection cost per component is $2.36 

- Average repair time is 4 hours per pump 

- Average repair time for valves = 10 minutes 

- Average repair time for connectors = 20 minutes 

- Average repair time for other components = 1 hr 

- All components need tags 

- Tagging a component takes 5 minutes and the cost of a tag is $2.36 

- Components inventory is entered in the database at 0.25 minutes per component and 

labor cost for data entry is $23.60/hr 

- Repair labor costs are $35.40 per hour 

- Equipment useful life is 10 years. 

The cost effectiveness of the LDAR program will be calculated using the emission reductions 

calculated in Chapter V and under the assumptions mentioned above. Table 6.1 - Cost 

Effectiveness for LDAR Program shows the cost effectiveness for the proposed LDAR program. 
CHAPTER 6 – COST AND COST EFFECTIVENESS 

Proposed Amended Rule 1173 6-3 May 15, 2007 

Table 6.1 

Cost Effectiveness for LDAR Program 

Number of Components 

Heavy Liquid Service 

Light Liquid Service 

Valves Pumps Connectors1 Others Total 

3,041 

3,712 

120 

98 

1,828 

2,409 

5,107 

7,193 23,508 

Capital costs ($) 

(Tags, tagging, data entry) 36,522 1,179 22,915 66,522 127,138 

Annual Costs ($) 

(Monitoring and repair)2

35,838 9,775 23,741 76,610 145,964 

Emission Reduction 

(TPY) 142.59 

Cost-Effectiveness 

($/ton) 919 

1: The number of connectors is assumed to be 25% of components (connectors, sight-glasses, meters, etc.) 

 reported in the other category of AQMD AER form R3 

2. Monitoring of all light liquid and gas/vapor valves and components and heavy liquid pumps quarterly 

3. Emission reductions for valves, pumps and connectors are calculated based on reported AER values 

4. BP Terminals 1 and 2 and Valero are already meeting the requirements of Proposed Amended Rule 1173 and 

 would not incur any additional costs. In addition, no emission reductions from these facilities were included in 

 the Cost-Effectiveness Calculations. 

Cost effectiveness = Present Value 

 Emission Reduction x Equipment 

Life 

 = 127,138 + ( 145,964 x 8.11) 

142.59 x 10 

= $919 per ton of VOC emissions 
CHAPTER 6 – COST AND COST EFFECTIVENESS 

Proposed Amended Rule 1173 6-4 May 15, 2007 

B. ELECTRONIC MONITORING DEVICES FOR ATMOSPHERIC PROCESS 

PRDs 

There is no emission reduction associated with this requirement of the rule. Therefore, cost 

effectiveness is not calculated. However, it is expected that the improved monitoring will 

ultimately result in reduced VOC emissions from PRD leaks and fewer PRD releases. Based on 

Compliance Plan data reported to the AQMD by the refineries as of 2005 there are 565 pressure 

relief valves on process equipment in gas service and venting to atmosphere. There were also 

another 205 pressure relief valves in liquid service venting to grade or drain with telltale 

indicators. Atmospheric PRDs that are in liquid service and are regulated under Rule 1176 will 

not be subject to the PRD electronic monitoring requirements of PAR 1173 if the operator can 

demonstrate that all released material meets the definition of heavy liquid. Staff estimates that of 

the 205 PRDs in liquid service, 50 percent of these will have to be equipped with tamper-proof 

electronic monitoring devices. 

Data provided by wireless industry representatives and a refinery that has installed ten electronic 

monitoring devices has indicated that the unit device cost ranged from $5,000 to $10,000 which 

includes device parts, installation and maintenance. The cost also includes the data retrieval 

system which may vary depending on the choice of contractor. It should also be noted that the 

cost of electronic monitoring systems is not linear and facilities requiring a larger number of 

monitors are expected to benefit from economies of scale. Based on these factors, staff has 

determined that the total cost of equipment and installation of electronic monitoring devices for 

the 657 PRDs (565 in gas/vapor service - 10 already installed by one facility + 102 in liquid 

service) is estimated to range from $3.3 million to $6.6 million. Annual operating costs are 

minimal because they include periodic replacement of inexpensive batteries.

C. PARAMETER MONITORING, OR USE OF TELLTALE INDICATORS IF 

ELECTRONIC MONITORING NOT FEASIBLE, FOR ALL ATMOSPHERIC 

PROCESS PRDs 

There is no emission reduction associated with this requirement of the rule. Therefore, cost 

effectiveness is not calculated. In most cases, at affected facilities, the process is controlled by 

computer systems that continuously monitor process parameters such as pressure, temperature, 

flow rates, etc. Daily parameter trends can be used to determine whether a release from the 

process equipment has occurred or not. Therefore, there is no cost involved with this 

requirement for those facilities equipped with process parameter monitoring systems. 

At facilities where process equipment is not controlled by a computer system and parameter 

monitoring is not available, the use of telltale indicators that would readily indicate a release is 

required. However, the cost associated with these indicators is expected to be minimal. 

D. INCREMENTAL COST EFFECTIVENESS 
CHAPTER 6 – COST AND COST EFFECTIVENESS 

Proposed Amended Rule 1173 6-5 May 15, 2007 

Health and Safety Code 40920.6 requires determination of incremental cost-effectiveness of 

potential control options, defined as “the difference in the dollar costs divided by the difference 

in the emission reduction potentials between each progressive/most stringent potential control 

option as compared to the next less expensive control option”. 

For components in heavy liquid service at lubricating oil and grease re-refiners and marine 

terminals, PAR 1173 requires quarterly inspections only for pumps in heavy liquid service. The 

most stringent requirement would be a LDAR program for valves, pumps and connectors in 

heavy liquid service with a quarterly inspection frequency. Emission reductions are then 

calculated assuming that all components in heavy liquid service will have an average emission of 

25 ppm after the LDAR program. The incremental cost effectiveness is shown in Table 6.2. 

Table 6.2 

Heavy Liquid LDAR Incremental Cost Effectiveness 

 Present Value 

($) 

Emission Reduction 

(Tons per Year) 

PAR 1173 

1,310,906 142.59 

Most Stringent Proposal 1,842,116 145.18 

Incremental Cost Effectiveness 

($/ton) 

205,100 

Incremental Cost = (1,842,116 – 1,310,906) / (145.18– 142.59) = $205,100/ton 
CHAPTER 7 – DRAFT FINDINGS 

Proposed Amended Rule 1173 7-1 May 15, 2007 

DRAFT FINDINGS 

Health and Safety Code Section 40727 requires that prior to adopting, amending or repealing a 

rule or regulation, the AQMD Governing Board shall make findings of necessity, authority, 

clarity, consistency, non-duplication, and reference based on relevant information presented at 

the hearing. 

Necessity - The AQMD Governing Board has determined that a need exists to amend Rule 1173 

for the following reason: to implement Control Measure FUG-05 – Emission Reductions from 

Fugitive VOC Sources of the 2003 Air Quality Management Plan (AQMP) by requiring a leak 

detection and repair program at lubricating oil and grease re-refiners and marine terminals and to 

reduce PRD releases by implementing an enhanced monitoring program. 

Authority - The AQMD Governing Board obtains its authority to adopt, amend or repeal rules 

and regulations from California Health and Safety Code Sections 39002, 40000, 40001, 40440, 

40702 and 41508. 

Clarity - The AQMD Governing Board has determined that Rule 1173, as proposed to be 

amended, is written or displayed so that its meaning can be easily understood by the persons 

directly affected by it. 

Consistency - The AQMD Governing Board has determined that Rule 1173, as proposed to be 

amended, is in harmony with and not in conflict with or contradictory to, existing statutes, court 

decisions or state or federal regulations. 

Non Duplication - The AQMD Governing Board has determined that Rule 1173, as proposed to 

be amended, does not impose the same requirements as any existing state or federal regulations, 

and the amendments are necessary and proper to execute the powers and duties granted to, and 

imposed upon, the AQMD. 

Reference - The AQMD Governing Board by adopting this regulation is implementing, 

interpreting or making specific the provisions of: Health and Safety Code Sections 40001 (rules 

to achieve ambient air quality standards), 40440(a), (rules to carry out the Air Quality 

Management Plan), (b) (Best Available Reftrofit Control Technology), and (c) (rules which are 

also cost-effective and efficient), 40702 (rules to execute duties) necessary to preserve original 

intent of rule) and 40910 et seq., (California Clean Air Act). 
CHAPTER 8 – CEQA 

Proposed Amended Rule 1173 8-1 May 15, 2007 

CALIFORNIA ENVIRONMENTAL QUALITY ACT 

Pursuant to California Environmental Quality Act (CEQA) Guidelines §15252 and SCAQMD 

Rule 110, the SCAQMD has prepared an Environmental Assessment (EA) for PAR 1173. The 

Draft EA was released for a 30-day public review and comment period from March 28, 2007 to 

April 26, 2007. No comment letters were received from the public relative to the Draft EA. The 

environmental analysis in the Draft EA concluded that PAR 1173 would not generate any 

significant adverse environmental impacts. 

Since the release of the Draft EA, minor modifications have been made to the document. 

However, none of the modifications alter any conclusions reached in the Draft EA, nor provide 

new information of substantial importance relative to the draft document. As a result, these 

minor revisions do not require recirculation of the Draft EA pursuant to CEQA Guidelines 

§15073.5. Therefore, the Draft EA is now a Final EA. 
CHAPTER 9 – SOCIOECONOMIC ANALYSIS 

Proposed Amended Rule 1173 9-1 May 15, 2007 

SOCIOECONOMIC ANALYSIS 

The proposed amendments to Rule 1173 (PAR 1173) would require petroleum refineries to 

install electronic monitoring devices on their pressure relief devices (PRDs) to improve 

monitoring and quantification of future potential releases of VOC emissions. In addition, the 

proposed amendments would require facilities that re-refine lubricating oils and greases and 

petroleum marine terminals to implement a leak detection and repair (LDAR) program. The 

implementation of PAR 1173 is projected to achieve a reduction of 0.40 tons in VOC daily. 

The proposed amendments will affect 22 facilities. All 22 affected facilities are located in Los 

Angeles County. The affected facilities belong to the sectors of petroleum refineries [North 

American Industrial Classification System (NAICS) 324110], petroleum lubricating oil and 

grease manufacturing (NAICS 324191), petroleum marine terminals (424710), and other 

warehousing and storage (493190). Table 9-1 shows the distribution of these facilities by 

industry. 

Table 9-1 

Number of Affected Facilities 

Industry (NAICS) 

Number of 

Facilities 

Petroleum Marine Terminals (424710) 11 

Petroleum Refineries (324110) 9 

Petroleum Lubricating Oil and Grease mfg.(324191) 1 

Other Warehousing & Storage (493190) 1 

Total 22 

Based on the assumptions in the staff report for PAR 1173, the annual cost of complying with 

PAR 1173 is estimated to be $0.72 million, on average, from 2008 to 2020. The $0.72 million 

cost is divided into $0.56 million for electronic monitoring devices on PRDs, starting in 2009; 

and $0.16 million for the LDAR program, starting in 2008. 

Table 9-2 has the distribution of the total cost by industry by year. Refineries would absorb 77 

percent (or $0.56 million) of the $0.72 million estimated cost. Since refineries are capital 

intensive businesses, the proposed amendments would have few job impacts on refineries. The 

job impacts on the rest of sectors in the local economy are expected to be small, or within the 

noise of the REMI model. Therefore, the REMI model was not used. 
CHAPTER 9 – SOCIOECONOMIC ANALYSIS 

Proposed Amended Rule 1173 9-2 May 15, 2007 

Table 9-2 

Estimated Annual Cost of 

Compliance (millions of 2006 dollars) 

Industry (NAICS) 2008 2009 2010 

Average 

Annual 

(2008-2020) 

Petroleum Refineries (324110) $0.00 $0.60 $0.60 $0.56 

Petroleum Marine Terminals (424710) $0.14 $0.14 $0.14 $0.14 

Petroleum Lubricating Oil and Grease 

Manufacturing. (324191) $0.01 $0.01 $0.01 $0.01 

Other Warehousing & Storage (493190) $0.01 $0.01 $0.01 $0.01 

Total $0.16 $0.76 $0.76 $0.72 

Rule Adoption Relative to the Cost-Effectiveness Schedule

On October 14, 1994, the Governing Board adopted a resolution that requires staff to address 

whether proposed rules being considered for adoption are presented in rank order by costeffectiveness as defined in the Air Quality Management Plan (AQMP). The proposed 

amendments implement part of VOC long-term measure commitment in the 2003 AQMP. This 

control measure was ranked seventh in the 2003 AQMP at $13,500 per ton of VOC reduced. 

The cost-effectiveness of PAR 1173 is estimated at $919 per ton of VOC reduced. The 

amendments were also proposed due to the concerns of Governing Board members about the 

high frequency, as well as high quantity of emission releases from total PRDs since the 

amendments to Rule 1173 in 2002. 
CHAPTER 10 – COMMENTS AND RESPONSES 

Proposed Amended Rule 1173 10-1 May 15, 2007 

COMMENTS AND RESPONSES 

Applicability and Definitions

Comment 1-1 

In the past, we have experienced issues with staff regarding the partial exemption of tagging and 

inspection for “extremely heavy liquids” and the requirements for heavy liquids. We request that 

the definition of Heavy Liquid be revised to include a statement that “extremely heavy liquids,” 

are not a heavy liquid. 

Response 1-1 

Staff believes that the rule is clear on the definition of heavy liquids as well as the partial 

exemption for the extremely heavy liquids. Staff also believes that any compliance 

implementation issues could be resolved through internal memoranda and inspector guidance. 

Comment 1-2 

The definition of facility should be amended to include marine terminals and lubricating oil and 

grease re-refiners. 

Response 1-2 

The definition of facility has been revised to incorporate this comment. 

Comment 1-3 

Definitions for Marine Terminal and Lubricating Oil and Grease Re-refiner have been added to 

the PAR 1173 to address the two new source categories. A definition for petroleum facility was 

also added to PAR 1173 and it includes these two source categories, in addition to refineries. 

The definition of Petroleum Facility is unnecessary and should be removed since PAR 1173 

provides definitions for Marine Terminal and Lubricating Oil and Grease Re-refiner. 

Response 1-3 

Staff has revised PAR 1173 to delete the proposed definition of Petroleum Facility and has added 

Lubricating Oil and Grease Re-refiner and Marine Terminal to the “applicability” for Rule 1173. 

Comment 1-4 

The definition for Marine Terminal should be revised to exclude SIC Code 4226 and be limited 

to only SIC Code 5171. 

Response 1-4 

In submitting their Annual Emissions Report (AER) to the AQMD, most marine terminals used 

SIC Code 5171 to identify the type of activities conducted at their facilities. However, some 

marine terminals have used SIC Code 4226 in their AER, which includes “petroleum bulk 

stations and terminals that are used for hire.” The AQMD can not mandate the use of any 

specific SIC Code for an industry. Therefore, the definition of Marine Terminal includes both 

SIC Codes 4226 and 5171. Other industries listed under SIC Code 4226 are not subject to PAR 

1173. 
CHAPTER 10 – COMMENTS AND RESPONSES 

Proposed Amended Rule 1173 10-2 May 15, 2007 

LDAR Requirements

Comment 2-1 

Extremely heavy liquids, such as lube oils in auxiliary lubrication systems, that are currently 

exempt from the identification (or tagging) and inspection requirements of the rule should also 

be exempt from other requirements (leak standard, maintenance and repair and open –ended line 

requirements and PRD requirements) of Rule 1173. These extremely heavy liquids have 

virtually no emissions to the atmosphere. 

Response 2-1 

Staff disagrees. Staff believes that although extremely heavy liquid releases are not expected to 

produce high vapor pressures due to their low boiling points, there is a potential for VOC 

releases if larger amounts of heavy liquids are allowed to leak. Therefore, the leak standards and 

maintenance and repair requirements will assist in controlling leaks and VOC emissions as is the 

case with lighter liquids and gases. As far as auxiliary lubrication systems, there can be leakage 

that would result in VOC contamination of the lube oil. When this type of contamination occurs, 

the overall vapor pressure of the lube oil can be significantly affected and result in substantial 

VOC releases. 

Comment 2-2 

Open-ended lines and valves which are located at the end of lines that are not sealed with a blind 

flange, plug, cap or a second closed valve at all times should be exempt from the leak standard 

requirements of the rule. 

Response 2-2 

Staff believes that since accessible pumps, compressors and atmospheric PRDs are required to be 

inspected only once during every eight-hour operating period and all other accessible 

components in light liquid/gas/vapor service are required to be inspected quarterly, there is the 

potential for large leaks to go undetected for significant periods of time. Therefore, the rule 

requirements serve to maintain the effectiveness of the existing LDAR program by minimizing 

the potential for these VOC releases. 

Comment 2-3

PAR 1173 should be amended to grant a leak standard exemption for open-ended lines and 

valves located on double-block and bleed systems similar to an exemption that exists in Federal 

Regulations (40CFR Sec. 60.482-6) that allows a bleed valve to remain open during operations 

that require venting the line between the block valves, but requires that the bleed valve remain 

closed at all other times with a cap, blind flange, plug or a second valve. 

Response 2-3

Staff believes that the scope of such an amendment is broad and would require significant review 

and discussion. However, staff would be willing to give consideration to this issue in future 

amendments of this rule. Staff has observed bleed valves which are part of double-block and 

bleed valve systems in the field and concurs that in these particular situations the bleed valves

fall into the category of open-ended lines. Subparagraph (d)(1)(E) already specifically addresses 

open-ended lines and valves located at the end of lines that are not sealed with a blind flange, 

plug, cap or a second closed valve at all times, except during operations requiring process fluid 
CHAPTER 10 – COMMENTS AND RESPONSES 

Proposed Amended Rule 1173 10-3 May 15, 2007 

flow through the open-ended line. Therefore, an amendment to address this comment is not 

needed.

PRD Requirements

Comment 3-1 

We believe that the requirement to implement enhanced monitoring of process PRDs should only 

be applicable to refineries. However, by using the definition of petroleum facility in the rule 

language, the requirement of enhanced PRD monitoring is also placed on lubricating oil and 

grease re-refiners and marine terminals. 

Response 3-1 

Staff’s proposed amendment to PAR 1173 is to require enhanced PRD monitoring for refineries 

based on their operation of equipment that has the potential to and have in the past released 

significant amounts of VOC to the atmosphere. Lubricating oil and grease re-refiners and 

marine terminals utilize atmospheric PRDs; however, the potential to release VOC is much less 

than that of the refineries. Therefore, PAR 1173 has been revised to remove the proposed 

definition of Petroleum Facility and has also been revised to require lubricating oil and grease rerefiners and marine terminals to monitor their atmospheric PRDs using process parameter 

instrumentation or telltale indicators where the use process parameter instrumentation is not 

feasible. 

Comment 3-2 

The enhanced process PRD electronic monitoring schedule should be amended to incorporate the 

following changes: 

A. For facilities with less than 50 PRDs, change the deadline for requiring facilities to have 

50 percent of all of their PRDs to be equipped with electronic monitors from July 2008 to 

January 1, 2009. 

B. For facilities with more than 50 PRDs, change the deadline for requiring facilities to have 

all inaccessible PRDs and 20 percent of all accessible PRDs, respectively, to be equipped 

with electronic monitors from July 2008 to January 1, 2009. In addition, in order to 

allow refiners flexibility, industry is requesting that reference made to monitors installed 

on inaccessible PRDs should be removed. 

Response 3-2 

The rule has been revised to incorporate these comments. 

Comment 3-3 

Larger facilities with greater than 50 atmospheric process PRDs should be allowed an additional 

two years to install electronic monitors on their PRDs. 

Response 3-3 

Staff believes that despite the fact that one facility has significantly more atmospheric process 

PRDs than all of the other affected facilities and will be required to install more electronic 

monitors, the time allowed is sufficient and the electronic monitor cost is not prohibitive to 
CHAPTER 10 – COMMENTS AND RESPONSES 

Proposed Amended Rule 1173 10-4 May 15, 2007 

trigger a delay in the PRD monitoring program for an additional two years beyond the rule 

schedule. However, at industry’s request, the deadlines have been extended by six months to 

January 1, 2009. 

Comment 3-4 

Some refineries may plan to route atmospheric process PRDs to vapor recovery and/or other 

control. Such projects require substantial time for planning and implementation. Can an option 

be made that would not require those PRDs to be monitored if these vapors were scheduled to be 

routed to a recovery and/or control system during the next turnaround after the July 2009 

deadline. 

Response 3-4 

Staff has revised PAR 1173 by adding subparagraph (h)(1)(F) that addresses atmospheric PRDs 

that are scheduled to be vented to vapor control systems or to vapor recovery systems during the 

next turnaround after December 31, 2008 for that process unit. Staff acknowledges that process 

of analyzing the feasibility, designing and planning a recovery and/or control project will take 

time. Refineries will be required to submit a revised compliance plan by December 31, 2008, 

that identifies the PRDs to be connected to a recovery and/or control system. However, staff will 

require that prior to connection to vapor recovery and/or control, these PRDs should be 

monitored by use of electronic process control instrumentation or telltale devices if such 

instrumentation is not feasible. This need to monitor is based on the PRD release data collected 

so far which indicates that there is the potential for process PRDs to release significant amounts 

of VOCs to the atmosphere. 

Comment 3-5 

The provision that allows refineries to delay installation of electronic monitors on a process unit 

PRD(s) by demonstrating to the satisfaction of the Executive Officer that the installation at an 

earlier date is not feasible or constitutes a safety hazard should be amended to allow the operator 

to install the electronic monitor(s) no later than the next scheduled turnaround for the process 

unit following the requirement to install the electronic monitoring device(s). 

Response 3-5 

Staff has amended the rule to allow industry to delay electronic monitor installation to no later 

than the next turnaround following rule adoption. Staff believes that allowing installation of 

electronic monitors by the process unit’s next scheduled turnaround following rule adoption 

should allow sufficient time for industry to complete any activities associated with the purchase 

and installation of the electronic PRD monitors. However, refineries must continue to monitor 

these PRDs by use of electronic process control instrumentation or telltale devices if such 

instrumentation is not feasible, as required by the current rule. 

Comment 3-6 

The atmospheric process PRD requirements of the rule should be amended to allow operators the 

option of utilizing either, a combination of tamper-proof electronic valve monitoring devices and 

continuous parameter monitoring or a combination of tamper-proof electronic valve monitoring 

devices and telltale devices in order to be able to record the duration of each release and to 

quantify the amount of compounds released, provided the operator can demonstrate to the 
CHAPTER 10 – COMMENTS AND RESPONSES 

Proposed Amended Rule 1173 10-5 May 15, 2007 

Executive Officer that either combination accurately represents the actual process condition at 

the PRD release location. We understand that the release duration and quantification will have to 

come from the electronic monitoring system. 

Response 3-6 

Staff has revised PAR 1173 to incorporate this comment. 

Comment 3-7 

PRDs in cooling water service should not be subject to the requirements of Rule 1173. PRDs 

that are located on cooling water systems are sized based on hydrocarbon leak from the process 

side of the exchanger. Any hydrocarbon leak to the water side of an exchanger is usually small 

and would not be large enough to require pressure relief from the cooling water system. In 

addition, the cooling water is usually analyzed and when hydrocarbon leaks occur they tend to be 

small and are detected and corrected before they cause an increase in the pressure of the cooling 

system. 

Response 3-7 

Staff agrees that the intent of PAR 1173 was not to address PRDs in cooling water service. 

However, staff will monitor the release of VOC containing materials into cooling water systems 

and take corrective measure if necessary in future rule development. 

Comment 3-8 

We appreciate the allowance for alternative monitoring for PRDs in liquid service as described 

by section (h)(1)(F). We recommend that the condition reference the existing definitions for 

light and heavy liquids for defining what PRDs are included as opposed to the existing language 

that requires all the material to ‘remain in a liquid state under atmospheric conditions’. This 

could be interpreted that any material exerting a measurable vapor pressure could not be included 

in this alternative monitoring approach. 

Response 3-8 

Staff has revised PAR 1173 subparagraph (h)(1)(F) to identify heavy liquids as the material from 

liquid PRDs that will not require PRD monitoring. Staff believes that VOC emissions from light 

liquids can be significant and that PRDs on light liquid lines must be monitored. 

Comment 3-9 

Please clarify that the intent of the rule is to allow different types of electronic monitors 

including pressure sensors on the inlet pipe of the relief valve (or a pressure sensor in close 

proximity to the PRD). In other words, the rule is not requiring the use of acoustic monitors. 

Response 3-9 

PAR 1173 requires refineries to monitor their atmospheric process PRDs through the use of 

tamper-proof electronic valve monitoring devices that can record the duration of each release and 

to quantify the amount of compounds released. An alternative PRD monitoring requirement 

allows refineries to monitor PRDs through a combination of tamper-proof electronic valve 

monitoring devices and continuous parameter monitoring or a combination of tamper-proof 

electronic valve monitoring devices and telltale devices in order to be able to record the duration 
CHAPTER 10 – COMMENTS AND RESPONSES 

Proposed Amended Rule 1173 10-6 May 15, 2007 

of each release and to quantify the amount of compounds released, provided the operator can 

demonstrate to the Executive Officer that either combination accurately represents the actual 

process condition at the PRD release location. Although acoustic monitors can be used as part of 

the monitoring system, the proposed amendments do not require the use of acoustic monitors. 

Comment 3-10 

Please clarify that we will be able to use manufacturer recommended settings on the electronic 

devices and/or other process data to establish what detection levels are sufficient to determine 

when an actual release has occurred to avoid false positives. 

Response 3-10 

In evaluating the proposed devices and equipment that will be used to demonstrate compliance 

with rules, staff typically will use manufacturer recommended settings. However, the final 

approval of the monitoring devices/system(s) will be completed as part of staff review of the 

compliance plan. 

Comment 3-11 

We appreciate the inclusion of an allowance to customize the schedule to install the monitors 

based on feasibility and safety considerations. However, it is not clear what will be deemed 

infeasible or a safety hazard when seeking approval from AQMD staff. We would define 

feasible as including, but not limited to, availability of monitor supply, delivery time of monitors 

and related components, etc. We believe that requiring a hot tap on a safety critical system 

presents a safety hazard and should be specifically mentioned in this condition. 

Response 3-11 

The proposed alternative schedule for installing electronic PRD monitoring devices stated under 

PAR 1173 subparagraph (h)(1)(D) allows refineries to delay installation of the monitors to no 

later than the next scheduled turnaround for that process unit with atmospheric PRD(s). Staff has 

contacted three manufacturers/distributors of wireless electronic valve monitoring 

devices/systems; all three manufacturers/distributors assured staff that these devices are readily 

available and can be delivered in a timely manner. The phrase “not feasible or constitutes a 

safety hazard” was developed to address the issue of “safe” installation of PRD monitors that 

will require hot tap on that PRD or accessibility to safely install the PRD monitor. However, 

staff is understands that the basis for delay of installation of monitors can also be due to activities 

which present a safety hazard as documented and established in a safety manual or policy and 

that these vary among the refineries. In circumstances where safety hazards are not documented 

or established in a safety manual or policy, the operator will still be required to demonstrate to 

the Executive Officer that the scheduled installation activity will present a safety hazard. Safe 

operation of facilities and the safety of the workers and the public, which includes the installation 

of monitoring equipment, are of the highest importance to the AQMD. 

Staff Report

Comment 4-1 

The rule refers to tamper-proof electronic monitors, but does not provide a definition. 
CHAPTER 10 – COMMENTS AND RESPONSES 

Proposed Amended Rule 1173 10-7 May 15, 2007 

Response 4-1 

A description, requirements and specifications of tamper-proof electronic monitors are included 

in the staff report. The definition of TAMPER-PROOF has been added to PAR 1173.

Comment 4-2 

It is not clear if the cost of wireless technology includes cost of installation and the cost of data 

transmission and analytical devices that are capable of accurate measurement of emission 

releases as required by the rule. 

Response 4-2 

The staff report has been amended to include a range of cost that includes installation and data 

retrieval. However, it should be noted that the PRD compliance plan for refineries with 

atmospheric process PRDs outlines a quantitative approach for calculation of VOC emissions 

based on the parameters measured by the electronic monitor that include temperature, pressure, 

flow rate and the composition of release streams. 

Comment 4-3 

A large portion of the technology assessment section in the staff report discussed the emerging 

new wireless technology, but did not provide adequate information regarding the analytical 

devices available in the market that are capable of accurately quantifying mass emissions from 

the PRDs. The staff report should include additional information regarding the analytical devices 

capable of accurately quantifying “the amount of the compounds released” that can be placed on 

the PRDs located on the process equipment. The staff report should also clarify the requirement 

for facilities to accurately quantify “the amount of the compounds released.” It is not clear if the 

proposed rule intends for the instrument to measure and quantify each compound released, or the 

total amount of all the compounds released. 

Response 4-3 

The proposed requirement to use electronic PRD monitoring devices is necessary to accurately 

determine that a release has occurred and the duration of that release. As you have stated, the 

staff report discusses the PRD monitoring device technology. However, the requirement to 

accurately quantify mass emissions from the PRDs is a current rule requirement that was 

developed during the 2002 Rule 1173 amendment. Mass emissions are calculated by use of the 

refinery’s process parameters instrumentation for that process equipment (which varies for each 

refinery) and the refinery’s knowledge of what materials are being processed. Calculation 

methodology and procedures are specified in their compliance plan. The rule does not specify 

type of analytical device. The current rule and proposed amendments require facilities subject to 

the PRD release requirements to measure and quantify the total amount of all the compounds 

released. 

Comment 4-4 

The staff report lists LDAR cost information from 2002; AQMD may wish to update this 

information. 
CHAPTER 10 – COMMENTS AND RESPONSES 

Proposed Amended Rule 1173 10-8 May 15, 2007 

Response 4-4 

Staff has updated the staff report to reflect the cost to implement LDAR at lubricating oil and 

grease re-refiners and marine terminals in 2007. 

Comments Received After PAR 1173 Noticed for Public Hearing

Comment 5-1

We suggest that the following bolded language and dates be added to improve clarity and 

implementation of PAR 1173:

• Lubricating Oil and Grease Re-Refiner Definition: Petroleum refineries engaged in the 

production of lubricating oils and greases are classified in Standard Industrial 

Classification Code 2911 and therefore are not included in this definition;

• Subparagraph (h)(1)(C): ...the operator of a refinery shall continue monitor all 

atmospheric PRDs...; 

• Subparagraph (h)(1)(E): ...provided that the operator demonstrates on or before the 

compliance dates in subparagraphs (h)(1)(A) and (h)(1)(B) to the satisfaction of the 

Executive Officer...; 

• Subparagraph (h)(1)G): The requirements of subparagraphs (h)(1)(A) through (h)(1)(F)

do not apply to atmospheric PRDs in liquid service that release to drains regulated under 

Rule 1176;

• Paragraph (h)(3): The operator of a lubricating oil and grease re-refiner or a marine 

terminal shall monitor atmospheric process PRDs located on process equipment by use 

of electronic process control instrumentation that allows for real time continuous 

parameter monitoring; 

• Paragraph (l)(6): Add Lubricating oil and grease re-refiners and marine terminals 

shall comply with the requirements of subdivision (e) no later than September 30, 

2007. The additional rule language is needed to ensure the appropriate components at 

these facilities are properly identified prior to the requirement for periodic inspection.

Response 5-1

Staff has revised PAR 1173 as suggested.

Comment 5-2

We acknowledge staff efforts to require enhanced monitoring of atmospheric process PRDs. We 

believe that venting all PRDs to vapor recovery is the much preferred method of control; even 

better than flaring. That being said, we are requesting that the staff post PRD release information 

on the AQMD website and reopen the rule if there is an increase in atmospheric PRD releases.

Response 5-2

Staff has in the past and continues to monitor the number, type and quantity of atmospheric 

process PRD releases, as well as any new technology which will improve the reduction and 

quantification of releases. In fact, the increase in atmospheric process PRD releases in 2003 and 

improvement in electronic monitoring that can be applied to atmospheric process PRDs is the 

basis of the proposed amendments to Rule 1173. Staff is also committed to amend Rule 1173 

when technologically feasible and cost effective control and measurement measures can be 
CHAPTER 10 – COMMENTS AND RESPONSES 

Proposed Amended Rule 1173 10-9 May 15, 2007 

implemented. Staff agrees that PRDs vented to vapor recovery and control is preferred to 

closely-monitored atmospheric process PRDs. However, with the current rule, refineries have 

connected some atmospheric process PRDs to vapor recovery and control. It should be pointed 

out that the refineries are committed to connecting atmospheric process PRDs to vapor recovery 

and control such that they have requested that alternative PRD monitoring (the currently required 

PRD monitoring using process unit operating parameters) be allowed until PRD connections to 

recovery and control are completed in the near term as required by PAR 1173. It is in the 

refinery’s best interest to recover useable fluids from PRD releases, but it also necessary to back 

up these recovery systems with flares for those extreme release scenarios. Lastly, staff will post 

atmospheric process PRD release information as practical and consistent with other AQMD 

rules.

Comment 5-3

Since refineries will no longer be able to choose the monitoring device to be installed based on 

the requirement of the new paragraph (h)(1) of PAR 1173, was the requirement for submittal of a 

revised compliance plan intended for facilities that are still allowed to make monitoring device 

selections?

Response 5-3

PAR 1173 paragraph (h)(1) will require refineries to implement electronic monitoring of 

atmospheric process PRDs, except for those case by case requests for alternative monitoring. 

The requirement that refineries submit a revised compliance plan is needed to update the 

atmospheric process PRD inventory that was submitted prior to January 2003; the updated 

inventory is needed to establish the number of electronic monitors that must be installed and 

operated pursuant the dates in subparagraphs (h)(1)(A) and (h)(1)(B) consistent with other 

alternative monitoring options under paragraph (h)(1) that may be approved. Subsequent revised 

plan(s) may be needed based on individual refinery turnaround schedules. Staff has added 

language under paragraph (h)(4) to clarify that lubricating oil and grease re-refiners and marine 

terminals will need to submit a compliance plan to establish their PRD inventory and monitoring 

option chosen; chemical plants only need to submit a revised plan if their PRD inventory has 

changed since their previous plan submittal.

Comment 5-4

Please clarify the monitoring, recordkeeping and reporting requirements for atmospheric PRDs 

associated with process equipment and other equipment.

Response 5-4

Rule 1173, as amended on December 6, 2002, requires refineries and chemical plants to monitor 

all of their atmospheric process PRDs, timely notify and report to AQMD specific releases, 

maintain specific records, and submit quarterly reports; and to notify and report to AQMD 

specific releases and maintain specific records associated with other equipment, including but 

not limited to storage tanks, pipelines and loading and unloading equipment. In addition to 

existing requirements, PAR 1173 will require enhanced monitoring of atmospheric process PRDs 

at refineries and will require lubricating oil and grease re-refiners and marine terminals to 

comply with the monitoring, recordkeeping and reporting requirements for atmospheric PRDs 

associated with process equipment and other equipment summarized in the previous sentence. 
CHAPTER 10 – COMMENTS AND RESPONSES 

Proposed Amended Rule 1173 10-10 May 15, 2007 

To improve the clarity of PAR 1173, staff has added the term “process” to atmospheric PRD in 

subdivision (h).

Comment 5-5

We request that AQMD continue to establish requirements that reduce emissions and improve air 

quality in communities near refineries and require the best monitoring technology for 

atmospheric PRD releases.

Response 5-5

PAR 1173 will require the use of electronic monitoring of atmospheric process PRDs that when 

used in conjunction with process parameter monitors for process equipment at the refineries will 

more accurately quantify emissions from a PRD release. PRD monitoring device technology has 

significantly improved since the 2002 Rule 1173 amendments (when staff initially evaluated 

PRD monitoring). The proposed enhanced monitoring is a method that will ultimately result in 

reduced emissions from atmospheric process PRD leaks and fewer PRD releases, which will help 

to improve air quality in communities near refineries. 

Comment 5-6

Please explain how the exemption from all rule requirements under subparagraph (l)(1)(D) 

relates to the definition of Heavy Liquid under paragraph(c)(10).

Response 5-6

Rule 1173 (l)(1)(D) [Exemptions] is used to determine whether components handling a mixture 

of fluids (gas/vapor and/or liquid) are subject to the rule. The determination is made by using 

ASTM Method D1945 for gas mixtures and SCAQMD Method 304-91 for liquid mixtures, both 

based on the VOC content by weight. Rule 1173 applies to components handling fluids that 

contain more than 10 percent VOC by weight and therefore, components exclusively handling 

fluids (liquid or vapor) with a VOC content of 10 percent by weight or less are exempted from 

Rule 1173 requirements. Once it is determined that the fluid is subject to Rule 1173, the next 

step is to determine whether the liquid meets the definition of “heavy liquid” or “light liquid.” 

Heavy liquids are defined as any liquid with 10 percent or less VOC by volume evaporated at 

150oC (302oF), determined according to ASTM Method D-86 on a by volume basis. Although 

both the exemption from the rule requirements and definition of heavy liquid include the words 

“10 percent or less,” the exemption is based on “by weight” test method, while the definition is 

based on “by volume,” test method, which are completely different standards.

Comment 5-7

We urge the AQMD to begin the process immediately for another amendment to Rule 1173 to 

require the control of all atmospheric process PRDs with a cost effectiveness analysis based on 

potential to emit.

Response 5-7

The December 2002 amendment of the rule has significantly improved the monitoring, 

recordkeeping and reporting requirements applicable to atmospheric process PRDs at refineries. 

Atmospheric process PRD release data that have been collected between 2003 and 2006 have 

indicated that the number of large releases was attributed to a very small fraction of the overall 

number of atmospheric process PRDs that were inventoried. In addition, the total amount of 
CHAPTER 10 – COMMENTS AND RESPONSES 

Proposed Amended Rule 1173 10-11 May 15, 2007 

VOCs released annually has decreased significantly and some refineries have already taken steps 

to connect their PRDs to vapor recovery or control. Connecting atmospheric process PRDs to 

vapor recovery or control and especially those have had no VOC emission releases can be a very 

costly and cost-ineffective strategy. Instead, staff’s proposal to amend the rule by requiring 

enhanced electronic monitoring of atmospheric process PRDs will better verify and quantify 

PRD releases and assist in identifying PRDs that can be cost-effectively controlled. Process 

PRDs release to prevent over pressurization of process equipment; these releases are random 

events. Potential to emit (PTE) may be the proper basis for continuous, semi-continuous and 

batch type operation, staff believes it is not appropriate to use PTE to determine cost 

effectiveness for random release events.

Comment 5-8 

The provision in the rule that allows refineries to pay a mitigation fee of $350,000 for VOC 

releases in lieu of connecting atmospheric process PRDs to vapor recovery or vapor control 

should be removed as part of this rule amendment.

Response 5-8

The pros and cons of a mitigation fee alternative were thoroughly argued during the December 

2002 rule amendment and ultimately approved by the Board. Although this option has been 

selected for some releases, there has been no evidence of abuse of this provision. Staff will 

continue to monitor releases and periodically report the status to the Stationary Source 

Committee of the Board. Should abuse of the provision become evident, staff would recommend 

a rule amendment.

Comment 5-9

Subparagraph (h)(1)(D) allows the refinery operator to delay the installation of tamper-proof 

electronic valve monitoring devices to no later than the next scheduled turnaround following rule 

adoption for that process unit PRD(s), provided that the operator demonstrates to the satisfaction 

of the Executive Officer that the installation at an earlier date is not feasible or constitutes a 

safety hazard. The AQMD should amend the rule to add a firm deadline to this PRD 

requirement to ensure that the delayed installation from monitoring equipment cannot be 

indefinitely put off.

Response 5-9

The propose rule requirement was included to specifically address situations where operators 

would need to delay installation of tamper-proof electronic valve monitoring devices until the 

next scheduled turnaround based on feasibility or safety concerns. This alternative monitoring 

option requires a request by the refinery through a compliance plan submittal and AQMD 

approval. Staff will closely monitor and ensure compliance that rule and compliance plan 

conditions and requirements are met. Establishment of a date certain in the rule does not 

ameliorate feasibility or safety concerns of installation that should not exist if installation was 

completed during the next turnaround.
CHAPTER 10 – COMMENTS AND RESPONSES 

Proposed Amended Rule 1173 10-12 May 15, 2007 

Comment 5-10

PAR 1173 should be revised to delete subparagraph (h)(1)(E) that weakens the requirement for 

direct and thorough monitoring of PRDs by allowing the use of some combination of monitoring 

at the PRD and parameter monitoring upstream at some other location.

Response 5-10

PAR 1173 requires that all petroleum facilities install and operate tamper-proof electronic 

monitoring devices that are capable of measuring the duration of each PRD release and 

quantifying the amount of VOC released from each atmospheric process PRD. Electronic 

monitors include devices that can measure pressure, flow, temperature or an acoustic measuring 

device that can be used to determine if PRD has opened. The proposed amendments allow a 

refinery to use a combination of electronic monitors and process parameters or electronic 

monitors and telltale indicators if the refinery can demonstrate that the proposed combination 

provides equivalent results at the PRD release point. Staff does not believe that this proposed 

alternative is a weakening of the electronic monitoring requirement, but in fact may actually 

provide additional methods and techniques to verify a PRD release.

Comment 5-11

The AQMD should consider controlling methane as an ozone reduction strategy and the staff 

analysis should be presented to the Stationary Source Committee early next year with a proposal 

to the full Board by next spring.

Response 5-11

Any approach by the AQMD to remove methane or other pollutants that are currently included in 

the list of exempt VOC compounds will not be dealt with as an issue isolated to PAR 1173 but 

would be analyzed as part of overall strategy to address current and future air pollution 

challenges, through a cooperative effort with the other appropriate state and federal regulatory 

agencies..
APPENDIX A – COMPARATIVE ANALYSIS 

Proposed Amended Rule 1173 A-1 May 15, 2007 

COMPARATIVE ANALYSIS 

Pursuant to Health and Safety Code Section 40727.7 staff has prepared an analysis of existing or 

proposed AQMD rules, regulations, requirements and federal air pollution control measures that 

apply to the same source type. 

Comparison of PAR 1173 and 40CFR60 VV, GGG, KKK and 40CFR63CC 

PAR 1173 40CFR60 VV, GGG, KKK, 40CFR63 

Applicability 

Components at refineries, chemical plants, 

lubricating oil and grease re-refiners, marine 

terminals, oil and gas production fields, 

natural gas processing plants and pipeline 

transfer stations. 

Affected equipment in petroleum 

refineries, synthetic organic chemicals 

manufacturing facilities, onshore natural 

gas processing plants. 

Requirements 

LDAR program for components in light 

liquid/gas/vapor service and pumps in 

heavy liquid service. Quarterly inspections 

with annual option after 5 quarters based on 

certain leak criteria. Inaccessible 

components inspected yearly. 

Pumps and valves inspected monthly. 

Valves in light liquid/gas/vapor service 

inspected monthly. After two monthly 

inspections without leaks, they may be 

inspected quarterly until a leak is detected. 

Leak threshold at 100 ppm for components 

in heavy liquid service. 

Leak threshold at 10,000 ppm for pumps 

and valves in heavy liquid service. 

Leak threshold at 500 ppm for components 

in light liquid/gas/vapor service. 

Pumps, valves, PRDs and connectors in 

light liquid/gas/vapor service leak 

threshold at 10,000 ppm. Compressors 

required to have a seal system with barrier 

fluid. PRDs in gas/vapor service leak 

threshold at 500 ppm. 

Leaks >500 but < 10K ppm - seven days 

repair. 

Leaks >10K but < 25K ppm - 2 days repair 

Leaks > 25K ppm 1 day repair 

Leaks > 10K ppm - 15 days repair 

maximum, first attempt at repair within 5 

days. 

Monitor all process atmospheric PRDs by 

use of combination of electronic monitoring 
APPENDIX A – COMPARATIVE ANALYSIS 

Proposed Amended Rule 1173 A-2 May 15, 2007 

PAR 1173 40CFR60 VV, GGG, KKK, 40CFR63 

devices and continuous parametric 

monitoring prior to July 1, 2010. 

Connect to control after any release greater 

than 2000 pounds of VOC or after second 

release or subsequent release greater than 

500 pounds VOC from same PRD within a 

5-year period. 

Lubricating oil and grease re-refiners and 

marine terminals must physically identify 

(tag) components and submit a compliance 

plan showing the location of the regulated 

components and comply with all other 

requirements commencing January 1, 2008. 

Recordkeeping and Reporting 

All leaks, repairs and re-inspections records 

to be submitted in electronic form as 

quarterly or annual report to AQMD. 

Submit semiannual reports containing the 

number of components, by type, that were 

repaired and for which repair was delayed, 

and the reason for delay. 

Report all releases exceeding 100 pounds 

VOC within 1 hour. Submit a written report 

within 30 days from the release. 

Submit quarterly PRD monitoring reports. 

Test Methods 

U.S. EPA Method 21 for leak screening, 

ASTM Method D86 for VOC content of 

light liquids and heavy liquids, ASTM 

Method D1945 for VOC content of gases, 

ASTM Method D93 for flash point of heavy 

liquids. 

U.S. EPA Method 21 for leak screening, 

ASTM E-260, E-168, E-169 for the VOC 

content, ASTM Method D-2879 for the 

vapor pressure. 

Exemptions 

Components that present a safety hazard Components that present a safety hazard 
APPENDIX A – COMPARATIVE ANALYSIS 

Proposed Amended Rule 1173 A-3 May 15, 2007 

PAR 1173 40CFR60 VV, GGG, KKK, 40CFR63 

Components handling exclusively natural 

gas 

Components handling gases with 10 percent 

VOC by weight or less and liquids with less 

than 10% VOC by weight and a flash point 

greater than 2500 F. 

Components handling fluids with less than 

10% by weight VOC. 

Components operating under negative 

pressure or totally enclosed, components 

buried underground. 

Components operating under negative 

pressure, pumps with a closed vent system, 

PRDs vented to a control device. 

Pressure vacuum valves on storage tanks. 

PRDs installed for thermal protection of 

liquid lines provided they are vented to a 

drain or back in the line. 

Components handling liquids with a flash 

point greater than 2500

 F. 

Releases caused by natural disasters, acts of 

terrorism and events beyond the petroleum 

facility’s control. 

Lubricating oil and grease re-refiners and 

marine terminals will not be subject to the 

requirements of the rule, except for the 

component identification and the PRD 

compliance plan submittal requirements 

until after December 31, 2007.