The Bay Area Air Quality Management District (BAAQMD or District) have released proposed Rule 8-18 amendments, the associated Staff Report, a socioeconomic impact analysis, the CEQA Initial Study and Negative Declaration, and supplementary emissions and cost information ahead of the public hearing to consider the adoption of the amendments. The amendments aim to reduce emissions of Total Organic Compounds (TOC) from equipment leaks at facilities that store, transport, and use organic liquids. These amendments mainly focus on select components in service of heavy liquids, the Leak Detection and Repair (LDAR) and operating requirements, increasingly stringent leak standards, and enhanced inspection and reporting requirements.
The BAAQMD is proposing amendments to Rule 8-18 after conducting a “Heavy Liquids Study” finalized in April 2022 with cooperation from the Western States Petroleum Association. The exigency for the study was as a part of a settlement agreement between the District and three refineries in 2016 after the previous Rule 8-18 amendments in 2015. Over the course of five years, BAAQMD collected data from petroleum refinery components handling material with an initial boiling point greater than 302oF to achieve a better understanding of the emission rates from similar refinery components. Data was self-collected using each petroleum refinery’s fugitive monitoring personnel and then audited by a third party overseeing the process. For more information please refer to the “
Fugitive Emissions from Petroleum Refinery Equipment in Heavy Liquid Service” study. BAAQMD’s Board of Directors will conduct a public hearing on September 4, 2024, at 10:00 AM to consider the adoption of the proposed amendments and adoption of its CEQA Negative Declaration.
BAAQMD Rule 8-18 Proposed Amendments
- 8-18-100 General:
- 101 Description: Adds plugs and gauges to the list of applicable equipment.
- 111 Exemption, Small Facilities: Now only applies to facilities that have less than 100 valves. Facilities with more than 100 valves but less than 10 pumps or compressors are no longer exempt.
- 113 Initial Boiling Point, Limited Exemption: Expands the requirements of this exemption. Connections, valves, and non-steam-quenched pump seals that handle organic liquids in the gaseous phase no longer qualify for this exemption. The exemption instead specifies connections that handle organic liquids with an initial boiling point greater than 302oF and valves and non-steam-quenched pump seals that handle the same liquids with an initial boiling point greater than 372oF.
- 119.3 Limited Exemption, Open-Ended Valve or Line: Exempts open-ended valves or lines that are either part of a lubrication system or contain non-process lube oil.
- 120 Limited Exemption, Non-repairable Equipment: This exemption will be deleted. Equipment exempted through this section were required to be repaired and replaced by December 16, 2020.
- 8-18-200 Definitions:
- 205 Equipment: Adds “sight-glasses”, “meters”, and “vessels” to the list of equipment components.
- 215 Process Area: Language updates to be inclusive of multiple units depending on size and complexity.
- 231-237: Adds seven definitions and specific clarification to the existing definitions for inaccessible equipment and process units and areas.
- 8-18-300 Standards:
- 306 Non-repairable Equipment: Mass emissions must be determined for any leak greater than or equal to 3,000 ppm.
- 8-18-400 Administrative Requirements:
- 401.12 Inspection: Includes semi-annual inspections of all valves handling organic liquids with initial boiling points greater than 302oF which were previously exempt.
- 404 Alternative Inspection Schedule: Removes reference of reverting to specifically to quarterly inspections and leaves generic as the original inspection schedule required from 8-18-401.
- 8-18-500 Monitoring and Records:
- 503 Reports: Clarifies that inspections records should be sent to the District at the end of every quarter within 30 days. Adds in requirements specifying that an update shall be provided to the District annually by February 1st describing any updates to records previously submitted to the District. Amendments also addressed reporting requirements for equipment due to the changes to the initial boiling point limited exemption.
The following amendments previously proposed in November 2023 have been removed from the latest draft amendments and are no longer considered for adoption at this time:
- 8-18-200 Definitions:
- 206 Inaccessible Equipment: A steam-quenched pump seal that cannot be inspected from 15 cm away is no longer classified as inaccessible.
- 231-232: Definitions for “Gaseous” and “Vapor” have been removed.
- 8-18-300 Standards:
- Emission leak standards are no longer proposed to be reduced from 500 ppm to 100 ppm and 100 ppm to 50 ppm.
- 308 Alternate Compliance: Section 8-18-313 is removed from the list.
- 312 and 313 Steam-Quenched Pump Seals that cannot be measured at a distance of 1 centimeter or less: Operating and repair requirements were removed.
- 8-18-400 Administrative Requirements:
- 401.3 Inspection: “Steam-quenched pump seals” removed from annual inspection.
- 401.13 Inspection: Removed requirement for 24-hour re-inspection for all equipment monitored by an instrument that shows a negative drift of more than 10% from its initial calibration.
- 8-18-600 Manual of Procedures:
- 602 Inspection Procedure: Removed additional requirements to EPA Method 21 inspections detailing the speed of the inspections, the calibration of instruments conducting inspections, and the distance of the inspection for steam-quenched pump seals.
Interested parties can read the proposed amended rule language and accompanying documents on
BAAQMD’s website.
If you would like to discuss the proposed amendments and how they may impact your facility, please contact Trinity’s
Oakland office or call
510.285.6351.
