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Proposed Amendments to BAAQMD Regulation 8, Rule 18: Equipment Leaks

August 30, 2024

What Are the Goals and Background of Proposed Rulemaking Regarding Equipment Leaks?

The Bay Area Air Quality Management District (BAAQMD) is proposing amendments to Rule 8-18, which would require that certain components in heavy liquid service be included in a Leak Detection and Repair (LDAR) program. Heavy liquids, defined as organic liquids with an initial boiling point above 302 degrees Fahrenheit (°F), are currently exempt from most BAAQMD monitoring. Examples of heavy liquids include diesel fuel, kerosene, turbine fuel, gas oils, and residuals.

The most efficient way to reduce emissions from fugitive leaks is a robust implementation of an LDAR program at subject facilities. When a leak above a detection threshold is discovered through monitoring, it must be repaired within a specified frequency.

What Facilities Are Impacted by the Proposed Amendment?

The BAAQMD anticipates that the proposed amendments will affect five refineries and seven non-refinery facilities, such as bulk loading plants and terminals, with an estimated magnitude of reduction of 146 tons per year of precursor organic compounds (POCs). The majority of anticipated emission reduction comes from reduced fugitive emissions from steam-quenched pumps and pressure relief valves at petroleum refineries.

Process streams handled by this equipment (e.g., joints, connections, valves, pressure relief devices, pumps, and compressors) have historically been categorized by phase, vapor pressure, and/or boiling point – i.e., as gaseous or vapor phase, light liquid (initial boiling point equal to or below 302°F), or heavy liquid (initial boiling point greater than 302°F).

What Actions Are Required for Affected Facilities?

Fugitive components in heavy liquid service will need to be included in each facility’s existing LDAR program. This will include monitoring of each component on a frequency determined by the component type, repair of any leaks detected, and providing the BAAQMD with piping and instrumentation diagrams (P&IDs) or technical drawings detailing which components are in heavy liquid service at each facility.

A public hearing will be held on September 4, 2024. Regulatory updates will go into effect 1 year after approval of this amendment.

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