UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

South Coast Air Quality Management District Rule 1114

Petroleum Refinery Coking Operations

Prepared by: James Shears

Reviewed by: Andrew Steckel

October 2014
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RULE IDENTIFICATION 

Agency: South Coast Air Quality Management District

SIP Approved Rule: None

Subject of this TSD: Rule 1114 – Petroleum Refinery Coking Operations

Adopted – May 3, 2013

Submitted – February 10, 2014

RULE SUMMARY – SCAQMD Rule 1114, Petroleum Refinery Coking 

Operations, is designed to minimize emissions generated during the delayed 

coking process by requiring that coke drums be depressurized to less than two 

psig prior to venting to atmosphere. Depressurization of delayed coking units to 

less than five psig is currently required of new refinery coking operations in EPA’s 

new source performance standard described in 40 CFR 60.103a(c), “Work 

Practice Standards”, July 1, 2011 edition. More stringent depressurization to less 

than two psig has been proposed by EPA as described in the Federal Register,

“Petroleum Refinery Sector Risk and Technology Review and New Source 

Petroleum Standards; Proposed Rule”, 79 FR 36879 (June 30, 2014).

SCAQMD regulates the South Coast Air Basin, which is an “extreme” nonattainment area for the 1-hour and 8-hour ozone NAAQS (see 40 CFR part 81). 

Rule 1114 is a new rule that is more stringent than 40 CFR 60.103a(c), but has 

equivalent stringency to the EPA-proposed rule (79 FR at 36900) for 

depressurization to less than two psig for appropriately capable or equipped

delayed coke units, and includes the following significant provisions:

1. Section (c) specifies that as of November 1, 2013, the owner or operator of 

a delayed coking unit shall depressurize each coke drum to less than two 

psig prior to venting it to atmosphere. As an alternative compliance 

procedure, the owner or operator of a single coking unit shall be required to 

depressurize each coke drum to less than five psig until the unit undergoes

turnaround and is upgraded after May 1, 2014 or by December 31, 2016. 

For facilities with multiple delayed coking units, the facility-wide average

coke drum internal pressure for all the coke drums must be submitted for 

the year 2012. Until turnaround and upgrading is completed between May 

1, 2014 and December 31, 2016, each coke drum, prior to venting to 

atmosphere, would be depressurized either to a pressure not to exceed 

110% of the 2012 facility-wide average submitted or to a pressure less than 

five psig, whichever is feasible. 
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2. Section (d) specifies that, effective November 1, 2013, the owner or 

operator of a delayed coking unit shall monitor the coke drum pressure and 

the coke drum atmospheric vent valve position, and record it continuously 

from feed introduction until atmospheric venting is initiated. If unable to 

comply with monitoring the vent valve position, the coke drum blowdown 

valve position or the temperature of the coke drum vent shall be monitored 

until coke drum turnaround and upgrading is completed. This must occur

between November 1, 2013 and December 31, 2016. The monitoring 

equipment must be maintained in good operating condition except during 

downtime periods for calibration, maintenance, or repair. The downtime 

shall not exceed 96 hours per year per coking unit. During downtime, the 

coke drum pressure and atmospheric vent valve position shall be manually 

recorded at five minute intervals beginning 15 minutes prior to atmospheric 

venting. All monitoring and downtime records shall be kept for at least 5 

years and shall be available to the Executive Officer on request (section f).

EVALUATION CRITERIA - The following criteria were used to evaluate the 

submitted rule. 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation 

Cutpoints, Deficiencies, and Deviations, EPA, May 25, 1988) and the Little 

Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 

2. Stringency – CAA §182(b)(2) requires that all areas (including South Coast) 

which are designated moderate or above nonattainment for national 

ambient air quality standards (NAAQS) for Ozone, must implement 

Reasonably Available Control Technology (RACT) for all major sources. 

Therefore, if there are major sources subject to Rule 1114, the rule should 

implement RACT. 40 CFR 60.103a, (Work Practice Standards, July 1, 2011

edition), and the proposed Petroleum Refinery Sector Risk and Technology 

Review and New Source Petroleum Standards; Proposed Rule, 79 FR 

36879, 36900 (June 30, 2014) were used to help evaluate the stringency of 

Rule 1114. There are no other state or local rules concerning coke drum 

venting pressure requirements.

3. SIP Relaxation – Where previous versions of rules have been SIP 

approved, new submittals must comply with CAA §110(l) and §193 

regarding SIP relaxation.

EPA EVALUATION – The submitted SCAQMD Rule 1114 is more stringent than 

40 CFR 60.103a(c) which only requires coke drum depressurization to less than 

five psig. Rule 1114 is equivalent in stringency to the EPA-proposed rule (79 FR 

36900) requiring depressurization to less than two psig for appropriately capable or 

equipped delayed coking units. This would significantly reduce the emissions 
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vented into the atmosphere, and is the most stringent such adopted requirement 

we are aware of. Rule 1114 has an alternative compliance process for coke drums 

only capable of meeting a five psig requirement, or greater, until they undergo 

turnaround and upgrading within the specified time period. The enforceability of 

the depressurization process would be substantially enhanced by requiring 

continuous monitoring of the coke drum pressure and atmospheric vent valve 

position to ensure that the unit is depressurized to less than two psig when the

valve is opened to initiate venting. All monitoring and downtime records must be 

kept for at least five years and be available on request.

1. The rule requirements and applicability are clear, and recordkeeping, 

reporting and other provisions sufficiently ensure that affected sources and 

regulators can evaluate and determine compliance with Rule 1114

consistently. 

2. The submitted rule is more stringent than 40 CFR 60.103a(c), and 

equivalent in stringency to the EPA-proposed rule (79 FR 36900). As a 

result, we have determined that this rule fulfils RACT requirements. 

3. We propose to determine that our approval of the submittal would comply 

with CAA §110(l) and §193 because (1) the proposed SIP-approved rule

would not interfere with the on-going process for ensuring that requirements 

for RFP and attainment of the NAAQS are met, and (2) the requirements in 

the submitted rule are more stringent than the existing SIP requirements.

EPA ACTION – The submitted Rule 1114 improves the SIP and complies with all 

relevant CAA requirements. Therefore, EPA staff recommends a full approval of 

Rule 1114 pursuant to CAA §110(k)(3).

REFERENCES1. SCAQMD Rule 1114, Petroleum Refinery Coking Operations, adopted into 

the SIP on May 3, 2013 and submitted to EPA on February 10, 2014.

2. 40 CFR 60.103a, Work Practice Standards, July 1, 2011 edition.

3. Federal Register Volume 79 Number 125, Petroleum Refinery Sector Risk 

and Technology Review and New Source Petroleum Standards; Proposed 

Rule, June 30, 2014.

4. The Little Bluebook, EPA Region 9, August 21, 2001.

5. The Bluebook, EPA, May 25, 1988.