Bay Area Air Quality Management District 

939 Ellis Street 

San Francisco, CA 94109 

Proposed Amendments 

Regulation 8 Rule 18: Equipment Leaks 

Control Measure SS-16 

Draft Staff Report

December 2003 

Prepared by: 

Victor Douglas 

Compliance and Enforcement Division 

Air Quality Specialist II 

Reviewed by: 

Wayne Kino 

Compliance and Enforcement Division 

Supervising Air Quality Specialist 

Jim Karas, P.E. 

Compliance and Enforcement Division 

Engineering Manager 

Kelly Wee 

Compliance and Enforcement Division 

Director 
TABLE OF CONTENTS 

EXECUTIVE SUMMARY ........................................................................................................1 

BACKGROUND ........................................................................................................................2 

PROPOSED RULE AMENDMENTS........................................................................................7 

EMISSION INVENTORY AND EMISSION REDUCTIONS..................................................9 

OTHER AREAS FOR POTENTIAL EMISSION REDUCTIONS .........................................11 

ECONOMIC IMPACTS...........................................................................................................13 

OTHER IMPACTS...................................................................................................................16 

CONCLUSIONS.......................................................................................................................18 
1 

EXECUTIVE SUMMARY 

Regulation 8, Rule 18 requires refineries to develop and implement a Leak Detection and 

Repair (LDAR) program to control fugitive emissions from valves, pumps, compressors, 

pressure relief valves, flanges, connectors, piping, and other equipment components. The 

rule, which includes the most stringent leak standards in California, also applies to 

chemical plants, bulk plants and bulk terminals. 

The proposed amendments to Regulation 8, Rule 8 ensure that best available control 

technologies are used for valves. The proposed amendments would: 

• Reduce the number of valves allowed on a non-repairable list; 

• Limit the number of valves on the non-repairable list with leaks of 10,000 parts 

per million (ppm) or more and ensure that emissions from each of these valves is 

less than 15 pounds per day; and 

• Allow connections to be placed on a non-repairable list at a ratio of one 

connection per two valves. 

The proposed amendments are intended to implement Control Measure SS-16 from the 

Bay Area 2001 Ozone Attainment Plan. That measure called for amendments to 

Regulation 8, Rule 18 that would require that replacement valves meet Best Available 

Control Technology requirements or that they be ìleaklessî valves. 

To implement the control measure, staff conducted numerous site visits to the Bay Area 

refineries and reviewed specific valve technologies to determine short-term and longterm emission performance. Staff found that no single valve type offered superior 

performance for the wide range of valve sizes and operating conditions encountered in a 

refinery, and that specifying valves for the many different situations encountered would 

be a complex undertaking with no clear benefits beyond those that come from the current 

rule. 

Staff determined that the existing valve leak standard of 100 ppm provides the best 

means to ensure that refineries use the best technology available for valve replacements. 

The 100 ppm standard is the most stringent in California (the South Coast AQMD leak 

standard for valves is 500 ppm) and is set at a level just above typical background 

concentrations. The amendments therefore implement the control measure by limiting 

the number of valves allowed on the non-repairable list, thereby ensuring the broadest 

possible application of the 100 ppm standard. 

During the rule development process for the amendments, refineries requested flexibility 

for connections that are very difficult to repair. Currently, connections must be repaired 

at any cost irrespective of emissions. To address this concern without increasing 

emissions, the proposed amendments would allow connections leaking below 10,000 

ppm to be placed on the non-repairable list at a ratio of one connection per two valves. 

The total number of valves and connections allowed on the list would continue to be 

determined strictly by the total number of valves in use at the refinery as documented 

annually. 
2 

These amendments will reduce emissions of organic and other pollutants, including toxic 

compounds. Staff has identified an emission reduction of 0.2 ton per day of precursor 

organic compounds. The expected total cost for all five Bay Area refineries to implement 

the proposed amendments is $23,500 to $118,000 per year. The cost effectiveness is 

approximately $320 to $1600 per ton of precursor organic compound emissions reduced. 

An analysis of the socioeconomic impacts of the proposal was prepared by Applied 

Development Economics of Berkeley, California. The analysis concludes that the 

economic and employment impacts to the Bay Area from the proposal would not be 

significant. 

A California Environmental Quality Act (CEQA) analysis for the proposed amendments 

has been prepared by Environmental Audit, Inc. of Placentia, California, concluding that 

the proposed amendments would not have any significant adverse environmental impacts. 

A Negative Declaration has been prepared for the proposed amendments pursuant to 

Public Resources Code ß 21080(c) and CEQA Guidelines 15070 et seq. and is being 

circulated for public review. 

The proposed amendments were developed through a workgroup that included District 

and ARB staff and representatives from environmental groups, the affected refineries, 

and the Western States Petroleum Association. The workgroup met six times in various 

locations. In addition, the proposal was discussed at a public workshop on October 28, 

2003 in Crockett. 

BACKGROUND 

There are five petroleum refineries within the jurisdiction of the District with 

approximately 233,000 total valves. The population of connections is estimated to be 

five times greater. The rule also applies to chemical plants, bulk plants and bulk 

terminals that have more than 100 valves or more than 10 pumps and compressors. The 

proposed amendments are not expected to significantly impact these smaller facilities. 

Regulatory History 

Rule 8-18 was first adopted in 1980 and was amended in 1992, with minor changes in 

1998 and 2002. Rule amendments adopted in 1992 significantly lowered the allowable 

leak concentration limits to the lowest in the country and required more effective 

inspection and repair programs in order to reduce emissions and promote selfcompliance. The 1992 amendments have reduced emissions by an estimated 1.2 tons per 

day. 

Rule 8-18 was last amended in November 2002 to address minor deficiencies identified 

by US EPA in their limited approval/disapproval of the rule. The U.S. Environmental 

Protection Agency (US EPA) fully approved the current rule in June 2003. 

Rule Development Process 

During the process to develop this proposed amendment to Rule 8-18, staff has worked 

extensively with the affected industry, interested public, and other air pollution control 
3 

agencies, such as the California Air Resources Board (CARB), US EPA and other air 

pollution control districts. 

Site Visits

Staff conducted numerous site visits to the Bay Area refineries to accompany both 

facility and district inspectors during Rule 8-18 inspections and learn how refinery staff 

carry out their leak detection and repair programs. These tours and the time spent in 

communication with both the inspectors and the representatives of the refineries were 

invaluable to the development of a balanced understanding of operations and 

technologies associated with the implementation of Rule 8-18. 

Literature Review and Information Requests 

Staff reviewed various sources of information regarding fugitive emissions, including 

bellow sealed valves, hermetically-sealed valves, fugitive emission rules of other 

California air districts, and reports provided by the refineries regarding their nonrepairable lists and leak detection and repair programs. 

Workgroup Meetings

During this rule development process, six workgroup meetings were held in various 

locations in the District. These workgroup meetings provided a forum in which technical 

and regulatory issues concerning this rule could be discussed in a effort to ensure that all 

participants had ample opportunity to voice their concerns and present comments and 

related information. In attendance at these meetings were industry representatives, 

environmentalists, CARB staff members, and district staff. 

Workshops

Staff hosted one workshop on October 28, 2003 in Crockett, to discuss draft amendments 

to the rule in a public forum. In attendance at the meeting were industry representatives, 

members of the public, environmentalist, and CARB staff members. 

Current Rule Requirements 

Each of the five refineries within the District has a leak detection and repair (LDAR) 

program. These programs function to ensure that all components are inspected regularly 

and, if a leak is found, the equipment is repaired, replaced, or placed on a list to be 

repaired. Under the current rule, there are four options under which a facility may 

comply with the rule: 

Option 1 – Leak Concentration Standard: This option allows the facility to 

inspect affected equipment for leaks; 100 ppm for valves and connections, and 

500 ppm for pumps, compressors and pressure relief devices. All equipment with 

leaks discovered by the facility must be minimized within 24 hours and repaired 

within seven days. All leaks discovered by the District must be repaired within 

24 hours. All equipment not subject to an LDAR program discovered to be 

leaking by District staff is a violation of this rule. 
4 

A fraction of the equipment that cannot be repaired may be placed on a nonrepairable list for up to five years or the next scheduled turnaround for that plant, 

whichever date comes first. The maximum fraction of components on the 

facility-wide turnaround list cannot exceed 0.5 percent for valves and 1.0 percent 

for pumps, compressors and pressure relief devices. Currently, connections are 

not allowed to be placed on a turnaround list. 

Option 2 – Mass Emissions Standard: This option allows the facility to use the 

concentration standards as trigger levels and measure any non-repairable 

component for mass emissions. Using the above Option 1 leak concentration 

standards as trigger levels, any non-repairable component can be measured for 

mass emissions. If the mass emission rate is greater than 15 pounds per day, the 

component must be repaired. If the mass emission rate is less than 0.1 or 0.2 

pounds per day, no further action is required. The number of components leaking 

between 0.1 or 0.2 and 15 pounds per day cannot exceed a small percentage of the 

total number of components at the facility. 

Option 3 – Reduced Inspection Frequency: Using the above Option 1 leak 

concentration standards as trigger levels, facilities can increase the interval 

between inspections for components that do not leak. This option reduces the 

cost of inspection and maintenance plans. The inspection frequency for 

equipment, except pumps and compressors, may be changed from quarterly to 

annually provided the equipment has been operated leak free for five consecutive 

quarters and records are submitted and approved by the District. If a leak is 

discovered, the frequency reverts back to quarterly inspections for that 

component. 

Option 4 – District Approved Inspection and Maintenance Plan: The final 

option allows facilities to implement an alternate program to reduce emissions 

from leaks. This option requires a written plan approved by the District and EPA. 

To date, no Bay Area refinery has elected to use this option. 

Other Air District Rules 

Several other air pollution control districts in California have rules that address fugitive 

emissions from refineries and chemical plants. These districts include the South Coast 

Air Quality Management District (Rule 1173), the San Joaquin Valley Unified Air 

Pollution Control District (4451 & 4452), and Ventura County Air Pollution Control 

District (Rule 74.7). In addition to these districtsí rules, the federal New Source 

Performance Standards affect emissions from equipment leaks. The table in Appendix A 

provides a simplified comparison of the major provisions of these rules with the 

provisions of the Districtís current rule. 

Overview of Current Leak Detection and Repair (LDAR) Programs 

Each LDAR program functions to ensure that all components are: 

• Identified; 
5 

• Labeled (except connections); 

• Inventoried; 

• Inspected for leaks; and 

• If found leaking, tagged, repaired, replaced, or placed on a non-repairable list. 

Identification: Each piece of equipment is uniquely identified in association with the 

plant at which it is located, the type of equipment, and a unique identification number. 

Labels: In addition, this identity is also placed on a label that is attached to each 

component or group of components. Labels contain varying degrees of information, but 

most will at least include the identification number. 

Inventory: Each piece of equipment is inventoried in a database that contains 

information on the equipment such as type, location, installation date, dates of inspection, 

leak concentration, and repair history. 

Inspections: Each refinery employs an inspection team that consists of either in-house 

employees or contractors.1 The inspection team calibrates their VOC detector, which is 

typically either a flame or photo ionization detector, and proceeds with the inspection. A 

member of the inspection team carries a monitoring device that reads and records 

information from a barcode or identifier attached to the component being inspected. If a 

leak is detected, a team member or another facility employee will attempt to minimize the 

leak as required by the rule. If the leak cannot be minimized, a team member will 

identify the component with a waterproof, indelible tag, upon which information 

regarding the leak is recorded and the component is identified for repair or replacement. 

Once the inspection is completed, the recorded information is uploaded into an LDAR 

data base. 

Technology Review 

The District reviewed equipment that could represent Best Available Control Technology 

for valves. 

Bellows Seal Valves

Bellows seal valves normally operate in a leak free manner because the moving 

components of the valve are hermetically sealed from the ambient air. Bellows seal 

valves function by replacing the packing and sliding or rotating seals with bellows 

(accordion-like tubing). This replacement eliminates the opportunity for emissions from 

the sliding of rotating seals and packing. However, failure of the bellows can result in 

significant emissions. 

 

1

 Three of the five Bay Area refineries employ independent contractors to conduct leak detection 

and repair inspections, and the remaining refineries utilize in-house employees. All refineries 

have a separate group dedicated to the task of leak detection and repair. 
6 

The bellows are sealed in two different ways. In one approach, the bellows are welded to 

the valve stem at the top and the valve body at the bottom. The process fluid is contained 

inside the bellows. In the approach, the bellows are welded to the valve stem at the 

bottom and the body on the top. The process fluid is contained in the annular region 

between the valve bonnet and bellows. 

Bellows valves are available only in a relatively narrow size range and could be used as 

replacements in only a small subset of all refinery applications. 

Solenoid-Actuated Valves

Solenoid-actuated valves are a departure from the standard air- or motor-operated valve 

design typically used for process fluid storage and handling of hydrocarbons. These 

valves are solenoid-actuated. They do not use stem, packing, or bellows. Further, 

solenoid-actuated valves isolate all moving parts within the process pressure areas. 

Because the actuator of these valves is completely sealed from the atmosphere and is 

actuated via magnetism, the potential for emissions due to the failure of seals surrounding 

dynamically moving parts is eliminated. However, failure of the isolation, such as a 

crack in the valve body can result in significant emissions. And, as with bellows valves, 

solenoid-activated valves could only be used in a limited range of refinery applications. 

ìBACTî Standard of the Control Measure

After reviewing specific valve technologies to evaluate short-term and long-term 

emission performance, staff concluded that the petroleum refineries must use the best 

technology available for replacements to consistently achieve the stringent emission 

standards of the rule ñ the 100 ppm leak limit for valves and 0.5 percent of the total 

number of valve allowed on a non-repairable list. Consequently, the strict emission 

standard combined with the limit placed on the non-repairable list constitutes a ìbest 

available control technologyî standard. 

As long as the refineries consistently meet this standard, the regulation need not dictate 

which technologies should be used. Rather, refineries should be allowed to use their 

expertise to determine the technology best suited for the conditions of use that will ensure 

compliance with the requirements of the rule. This approach will allow the introduction 

of improved technology that may ìcross overî from other industrial application without 

requiring an exhaustive review process to maintain a BACT list. 
7 

PROPOSED RULE AMENDMENTS 

The proposed amendments: 

• Reduce the number of valves that are allowed on the non-repairable list; 

• Limit the number of valves leaking in excess of 10,000 ppm; 

• Require mass emission rate determinations for valves leaking in excess of 10,000 

ppm and control those with excess emissions; and 

• Allow connections with leaks that do not exceed 10,000 ppm to be placed on the 

non-repairable list at a ratio of one connection per two valves. 

The amendments are made possible by improvements in the ability of the refineries to 

locate and repair leaking components and improvements in valve technology, such as 

hermetically sealed valves and advancements in valve stem packing materials. These 

improvements, which are already being implemented in some areas, have led to emission 

reductions that have not yet been credited to this rule. By implementing the 

improvements across the board, additional emissions reductions will be achieved. 

Finally, the amendments will ensure that the components that are believed to be 

responsible for the greatest emissions are examined and if found to have excessive 

emissions, controlled. 

Reducing the Number of Components on the Non-Repairable List 

The non-repairable list was established to provide a mechanism to address essential 

components. Essential components are those pieces of equipment that cannot be repaired 

or replaced unless the process unit is shutdown and the component is isolated. This 

activity would likely create more emissions than the actual fugitive leaks. The rule 

allows a certain percentage of each type of equipment to be placed on the list. Table 1 

indicates the current allowable fractions of each component on the non-repairable list. 

Table 1 

Current Allowable Limits for Components Awaiting Repair or Replacement 

Equipment Fraction of Non-repairable 

Equipment Allowed 

Maximum Duration 

Valves 0.5% 5 years or next turnaround 

Pressure Relief Devices 1 % 5 years or next turnaround 

Pumps/Compressors 1 % 5 years or next turnaround 

Data collected from the refineries indicate that the current LDAR programs implemented 

at some refineries result in a much lower fraction of leaking equipment being placed on a 

non-repairable list than the fraction allowable by Rule 8-18. This suggests that it is 

possible to reduce the percentage of equipment allowed on the non-repairable list or 

address non-repairable equipment in a different manner. 
8 

Staff proposes to modify the allowable fractions according to the table below. 

Table 2 

Proposed Revisions to the Allowable Limits for Components Awaiting Repair or 

Replacement 

Equipment Number of Non-repairable 

Pieces of Equipment Allowed 

Maximum Duration 

Valves (including valves with 

major leaks) and connectors 

0.3% of total number of valves 5 years or next turnaround 

Valves with major leaks 0.025% of the total number of 

valves 

5 years or next turnaround 

Pressure Relief Devices 1.0% total number of PRVs 5 years or next turnaround 

Pumps/Compressors 1.0% total number of pumps and 

compressors 

5 years or next turnaround 

In this proposal, the fraction of valves (including valves with major leaks) allowed on the 

non-repairable list would be reduced from 0.5 percent to 0.3 percent. 

Concentration Limit for Non-repairable Components 

The proposal will also limit the number of valves leaking in excess of 10,000 ppm to 

0.025 percent of the total number of valves in operation at the facility; these valves would 

be included in the number that make up the 0.3 percent allowed for all valves. Before a 

valve with a major leak (one that leaks in excess of 10,000 ppm) can be placed on the 

non-repairable list, its mass emission rate must be determined and found to be below 15 

pounds per day. In addition, the mass emission rate must be determined at least once per 

year to ensure that the leak does not exceed the 15-pound limit. This provision is 

intended to prevent a component from leaking an indefinite amount of mass emissions for 

up to five years. 

The amendments will require refineries to take action on valves that are found leaking in 

excess of 10,000 ppm (50 to 100 times the allowable limits). If a component is found to 

leak in excess of 10,000 ppm, the operator must do one of the following: (1) minimize 

the leak below 10,000 ppm within 24 hours and repair the component within seven days, 

or (2) measure the mass emission rate of the leak and place the component on the nonrepairable list only if the mass emission rate is less than 15 pounds per day. If the valve 

leaks in excess of the allowable mass emission rate, then the operator must either repair 

or replace that component or capture and vent those emissions to a control device. 

Additionally, the refiner must notify the District of each mass emission rate 

determination at least 96 hour prior to the determination. This will allow the District to 

review the process of the emission rate determination and also allow concurrent testing of 

the leaking component for methodology evaluation. 

Connections on the Non-repairable List 

The refineries have long asserted that regulatory flexibility is needed for connections that 

pose difficulty in repair. To address this concern, staff proposes allowing connections 
9 

with leaks less than 10,000 ppm to be placed on the non-repairable list in a very limited 

fashion that would not result in a relaxation of the rule. To ensure that any emissions 

associated with a connection being placed on the non-repairable list are offset, the 

amendments would require that each connection placed on the list counts as two pieces of 

equipment. The number of components allowed on the list is strictly limited to the 

number of valves located at the refinery multiplied by the allowed fraction. For example, 

if a refinery has 50,000 valves and the fraction of valves allowed on the non-repairable 

list is 0.3 percent, then the number of valves allowed on the list could not exceed 150. 

Additionally, for each connection allowed on the list, two spaces of the 150 allotted for 

valves would no longer be available. 

EMISSION INVENTORY AND EMISSION 

REDUCTIONS 

Emission Inventory 

Emission inventory data collected over the past several years indicate that fugitive 

emissions have been constantly decreasing. Table 3 details these emissions and 

reductions. There was a significant emissions reduction between the 2001 inventory and 

the current modified 2002 inventory. This emission reduction is due mostly to the 

adoption of new correlations factors from the EPA that are published in the ARBís 

"California Implementation Guidelines for Estimating Mass Emissions of Fugitive 

Hydrocarbon Leaks at Petroleum Facilities.î However, notwithstanding the change in 

correlation factors, there has been a general downward trend to fugitive emissions over 

the last several years. This trend is largely due to improvement in the leak detection and 

repair programs over time. 
10 

TABLE 3 

Estimated Emissions Inventories for All Fugitives Components1

SIP 

(Modified 

1999 

Inventory)1

2000 

Inventory2

2001 

Inventory2

Current 

(Modified 

2002 

Inventory) 2,3,4

Refinery (organic emissions - pounds/day) 

Chevron 7 ,821 7,821 7,773 2,294 

Shell 352 352 351 381 

ConocoPhillips 1,543 1,543 1,473 1,474 

Valero Asphalt 35 35 35 22 

Valero 1,969 530 257 332 

Tesoro 1,690 1,690 1,688 128 

Total (tons/day) 6.71 5.99 5.79 2.32 

1. These are the estimated fugitive emissions from all components affected by Rule 8-18, including 

valves, pumps, compressors, pressure relief devices, and connections. 

2. The annual emission inventories are based on equipment counts provided to the District by each 

refinery. 

3. The values in this column reflect the use of modified correlation factors for each component 

category, as published in the ARBís "California Implementation Guidelines for Estimating Mass 

Emissions of Fugitive Hydrocarbon Leaks at Petroleum Facilities.î 

4. These values are currently under review and may not reflect the final emission inventory for 2002. 

Emission Reductions 

The emission reductions for the proposed amendments are presented in Table 4. These 

emission reductions are based on the assumption that all leaking components other than 

connections will be discovered at the five Bay Area refineries. 

TABLE 4 

Emission Reduction Estimates1. 

Rule 8-18 Emissions2

(lbs/day (TPD)) 

Amended Rule 8-18 

Emissions3 

(lbs/day (TPD)) 

Emission Reductions 

(lbs/day (TPD)) 

Valves 706 (0.35) 303 (0.15) 403 (0.20) 

1. Assumes a total of 233,000 valves at all five Bay Area refineries (see Table 5). 

2. Assumes that the total number of valves leaking is 0.50 percent of all valves. 

3. Assumes that the total number of valves leaking is 0.30 percent of all valves and that fraction 

leaking above 10,000 ppm is 0.0025 percent. 

Staff estimates that there are approximately 233,000 total valves at the five Bay Area 

refineries. Table 5 presents the inventory for valves, pump and compressors, pressure 

relief devices, and connections. 
11 

TABLE 5 

Estimated Inventories1

 of Various Components Subject to Rule 8-18 

at the Bay Area Refineries

Refinery Components 

Valves Pumps and 

Compressors 

Connections 

Chevron 71,000 800 355,000 

ConocoPhillips 27,000 250 134,000 

Shell 52,000 360 217,000 

Tesoro 33,000 1500 156,000 

Valero 50,000 300 250,000 

TOTALS 233,000 2110 1,112,000 

1. These values are based on quarterly reports and direct quotes from industry representatives. 

OTHER AREAS FOR POTENTIAL 

EMISSION REDUCTIONS 

During this rule development process, staff examined other strategies that have some 

potential for achieving emission reductions. These strategies are not included in this 

rulemaking because they require further study. Each potential strategy examined by staff 

is discussed briefly below. 

Maximum Leak Limit for All Components 

District staff examined whether a maximum leak standard should be established and 

whether it would reduce emissions. The BAAQMD rule and many other air district 

fugitive rules allows repair to be deferred for a small number of valves that exceed leak 

limits. These allowances are intended to avoid the potentially significant emissions that 

could come from shutting down a unit to make repairs. On the other hand, emissions 

from components with significant leaks awaiting repair could be potentially significant. 

There is limited data available to determine whether a focus on leaks with concentrations 

over an established maximum is warranted. For individual components, the available 

data suggests that the correlation between mass emissions and concentration is poor. It 

may be more appropriate to focus on a mass emission approach. The proposed 

amendments will require the facilities to measure mass emissions on leaking valves over 

10,000 ppm leak concentrations. This data will help determine if a mass emission or a 

maximum concentration is warranted. Additionally, an initial assessment of data 

reported by the Bay Area refineries indicate that less than one in 5000 valves leak in 

excess of 10,000 ppm, which is less than ten at any one refinery. Only a very small 

fraction of these components are expected to have mass emissions rates in excess of the 

preset limits. Emission reductions may therefore be quite limited and need further 

examination. 
12 

Violations for Leaks Detected During District Inspections 

The current rule allows refineries 24 hours to repair leaks found by District inspectors 

and seven days to repair leaks discovered by refinery. An alternative would be to treat as 

a violation the detection of leaks by District inspectors in a specified percentage of the 

components inspected. The South Coast fugitives rule uses such an approach. This 

might encourage more thorough inspections by refinery personnel. On the other hand, 

refiners expressed concerns that even with good LDAR programs, it is possible to find 

leaks, particularly if a District inspector chooses to inspect an area that is due for 

inspection but has not yet inspected under the refinery LDAR program. Refiners felt that 

this might be perceived as unfair and might not improve the refinery program. 

Accelerated Replacement of Equipment with Frequent Leaks/Repairs 

Some specific components appear to be more prone to leaks and to require more repair. 

The rule could require a component to be replaced if the number of leaks within a 

specified time period exceeds a threshold specified in the rule. The South Coast and 

Ventura rules use this approach. On the other hand, it may be true that more frequent 

repair is required for certain demanding types of service, and any replacement component 

will have the same failure rate. 

Replacement of Inaccessible Equipment with Superior Technologies 

Replacement of inaccessible equipment with superior technologies could reduce the 

potential for emissions. Regulation 8, rule 18 requires less frequent inspection for these 

components. This reduced inspection frequency results in a longer average time period 

before a leak is detected and repaired. It is unclear whether superior technologies can be 

readily identified. 

Control Emissions from Heat Exchangers 

Heat exchangers are potential sources of VOC emissions through leakage of VOCs into 

cooling liquid and subsequent emission at cooling towers. A first step would be to 

measure VOC emissions at cooling towers over an entire cycle to determine whether 

emissions are significant. To determine if a leak exists in a heat exchanger, the VOC 

concentrations of cooling water at the inlet and outlet to the heat exchanger could be 

compared. A higher VOC concentration at the outlet would indicate a leak. This work 

would have to be done to determine whether there is any potential for emission 

reductions. 

Quantification of Mass Emissions and Emission Caps 

If mass emissions for leaking components can be reliably determined, a cap could be 

placed on total emissions from equipment placed on the non-repairable equipment list. 

Leaking equipment could be added to the list, but only if the total fugitive emission cap is 

not exceeded. If adding a leaking component would cause the cap to be exceed, 

emissions from equipment already on the non-repairable list would have to be reduced. 
13 

This approach would provide an incentive to replace high-emitting equipment on the list 

as soon as possible and would provide a facility flexibility to make the most cost 

effective choices that results in the least emission consequence. On the other hand, a 

mass emission cap could be overly complex and difficult to administer. 

Increase Inspection Frequencies 

Increasing the frequency of inspections would reduce the time that a leaking component 

goes undetected, and could decrease emissions. To implement increased inspection 

frequencies, additional staffing would be required. Staff would have to further assess 

potential emission reduction benefits from increased inspection frequencies. 

Smart LDAR 

The U.S. EPA and API have jointly worked on a project called ìSmart LDARî through 

the U.S. EPAís Common Sense Initiative for the Petroleum Refining Sector. Research 

indicates that a small subset of all leaking components is responsible for most of the 

emissions. Rather than focus efforts on controlling minor leaks, the Smart LDAR project 

is examining the use of remote sensing methods that would allow quick identification and 

repair of leaks causing large emissions. It is unclear when those methods will become 

available for routine use in refinery LDAR programs. 

ECONOMIC IMPACTS 

Costs 

The costs associated with the proposed amendment are primarily the costs of determining 

the mass emission rates of valves leaking in excess of 10,000 ppm and the cost of 

controlling component with emissions above the 15-pound limit. There are two methods 

that were identified as reliable methods of determining mass emissions: high volume 

collection system (HCVS) and the US EPA vacuum method. These methods are 

described and compared in Appendix B. 

Table 6 compares the cost of each of these methods. The cost values in Table 5 have 

been inflated from 1995 values using inflation factor of 1.2 obtained from the US 

Department of Labor, Bureau of Statistics (www.bls.gov). 

TABLE 6 

Cost Estimates for Mass Emission Rate Determinations 

HCVS Vacuum Method 

Total time required for ONE sample1 4 hours Two days 

Labor Cost per sample ($450/day) $225 $900 

Lab Cost per sample $0 $400 

TOTAL COST per sample $225 $1300 

1. This represents the time needed to sample one valve and not a population of valves. This value is 

based on the assumption that valves leaking in access of 10,000 ppm would be found individually and, 

therefore addressed individually. Further, it is expected to take at least a half day to prepare the 
14 

instrumentation (calibration and flow rate determination) for the high volume sampler and two days to 

enclose the leaking component and prepare for sampling (calibration and flow rate determination). 

Based on current inspection data, it was estimated that a total of 60 valves may need mass 

measurements. Using the cost estimates from Table 6, the cost of sampling 60 valves 

annually was estimated between $13,500 and $78,000. The cost to capture, vent and 

control emissions from a valve with excess emissions can range from $5,000 to $20,0002 

each depending on the valve size, location (accessible or inaccessible, proximity to a vent 

for flare or fire box, spatial proximity to other components, etc.). It was estimated that 

2.5 percent of valves leaking in excess of 10,000 ppm will have emissions of 15 pounds 

per day or greater,3 or 2.5 percent. That is approximately two valves District-wide that 

could potentially be required to be controlled. This would result in a potential cost of 

$10,000 to $20,000 to reduce 5.5 tons of emissions or a cost effectiveness that range 

between $1,800 and $3,600 per ton reduced. The annual costs associated with these 

proposed amendments are presented in Table 7. 

TABLE 7 

Costs of the Proposal

Requirement Annual Costs 

Mass Emission Rate Determinations $13,500 -$78,600 

Control of Valves with Excessive Leaks $10,000 to $40,000 

TOTAL COSTS $23,500 to $118,000 

The emission reduction that will result from this proposal is estimated to be 

approximately 74 tons per year. This results in a potential cost effectiveness range of 

$320 to $1,600 per ton of precursor organic compounds District-wide. 

Incremental Costs 

Under Heath and Safety Code section 40920.6, the District is required to perform an 

incremental analysis when adopting a Best Available Retrofit Control Technology 

(BARCT) rule or feasible measure required by the California Clean Air Act. To perform 

this analysis, the District must (1) identify one or more control options achieving the 

emission reduction objectives for the proposed rule, (2) determine the cost effectiveness 

for each option, and (3) calculate the incremental cost effectiveness of each option. To 

determine incremental costs, the District must ìcalculate the difference in dollar cost 

divided by the difference in the emission reduction potentials between each progressively 

 

2

 This cost range is based on personal conversations between District staff and staff members of 

the California Air Resources Board and refinery personnel. 

3

 Emissions estimates provided by WSPA. 
15 

more stringent potential control option as compared to the next less expensive control 

option.î 

This regulatory development process was initiated to examine the feasibility of drafting 

amendments to Regulation 8, Rule 18 that would implement Control Measure SS-16 

from the Bay Area 2001 Ozone Attainment Plan. To implement Control Measure SS-16, 

staff evaluated requiring replacement valves that meet BACT requirements or that they 

be ìleaklessî valves. Staff has concluded the performance standard in the current rule 

combined with the limit placed on the non-repairable list constitutes the ìbest available 

control technologyî and that no additional provisions are necessary or appropriate to 

ensure that refineries meet that standard of the rule. 

In addition, during this rule development process, staff examined various alternatives to 

achieve the emissions reduction required under the 2001 Ozone plan. The first option 

considered was to require all valves placed on the non-repair list to be repaired or 

replaced with hermetically-sealed valves. This option would be extremely expensive. 

Bellow seal valves cost approximately $12,000, which is about $7000 more than a typical 

valve. Two tenths of a percent of the total number of valves (233,000), could be placed 

on the non-repairable list for up to five years (46,600 valves). It is expected that about 

half of these valves would need to be replaced with bellow seal valves or 23,300 valves. 

Because the valves can remain on the list up to five year, 20 percent of the valves would 

be cycled out each year (4660 valves). This type of an approach would result in an 

annual cost of $32 million. The second option considered is outlined in this proposal. A 

comparison of the alternative and this proposal is summarized in Table 8. 
16 

TABLE 8 

Incremental Cost Analysis 

Annual Emissions 

Reductions 

Annual Costs Cost Effectiveness 

Replace Valves with 

Hermetically-Sealed 

Valves 

Negligible1

 $32 million Indeterminate 

The Proposal 74 tons $23,500 to $118,000 $320 to $1,600 per ton 

1. Specific emission reductions cannot be credited to the replacement of valves 

with bellow seal valves because all valves must meet the 100 ppm standard and 

limits on the non-repairable list. 

Socioeconomic Impacts 

Section 40728.5 of the Health and Safety Code requires an air district to assess the 

socioeconomic impacts of the adoption, amendment, or repeal of a rule if the rule is one 

that ìwill significantly affect air quality or emissions limitations.î Applied Economic 

Development of Berkeley, California, has prepared the required cost analysis. (Appendix 

D) 

OTHER IMPACTS 

Environmental Impacts 

The Districtís environmental consultant, Environmental Audit, Inc., prepared an initial 

study for the proposed rule amendments to determine whether rule adoption would result 

in any significant environmental impacts. In general, the initial study concludes that the 

proposed amendments would result in environmental benefits by reducing the number 

and magnitude of leaks for which repairs can be deferred under existing rule provisions. 

The complete environmental document is attached as Appendix C. A Negative 

Declaration for the proposed amendments has been prepared and is being circulated for 

comment. The comment period is from December 22, 2003 to January 12, 2004. 

Regulatory Impacts 

California Health and Safety Code section 40727.2 requires the District to identify 

existing federal air pollution control requirements for the equipment or source type 

affected by the proposed rule or regulation. The District must then note any differences 

between these existing requirements and the requirements imposed by the proposal. 

Regulation 8, Rule 18: Equipment Leaks applies to fugitive emissions from valves, 

pumps, compressors, pressure relief devices, connection and any other component that 

may have fugitive leaks. The proposal does not expand the applicability or the current 

rule. 
17 

Numerous federal requirements apply to fugitive emissions at the facilities subject to 

Regulation 8, Rule 18. New sources are subject to New Source Performance Standards 

found in 40 CFR Part 60, Subpart VV (Equipment Leaks of VOC in the Synthetic 

Organic Chemicals Industry) and Subpart GGG (Equipment Leaks of VOC in Petroleum 

Refineries). Other sources are subject to National Emission Standards for Hazardous Air 

Pollutants (NESHAPS) found in 40 CFR Part 61, Subpart V (National Emission 

Standards for Equipment Leaks (Fugitive Emission Sources)), and to 40 CFR Part 63, 

Subpart CC (National Emission Standards for Petroleum Refineries). A comparison 

between BAAQMD and federal requirements follows: 

BAAQMD Reg. 8, Rule 18 40 CFR60 VV, GGG, 40 CFR63 CC 

Applicability

Components at petroleum refineries, chemical 

plants, bulk plants and bulk terminals. 

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. Quarterly inspections. 

Inaccessible components inspected annually. 

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 valves, 

connectors, 500 ppm for pumps, compressors 

and PRDs in gas/vapor/light liquid service. 

Leak threshold at 10,000 ppm for pumps and 

valves in heavy liquid service. 

Leaks detected by operator minimized within 

24 hours and repaired within 7 days. 

A percent of non repairable components may 

delay repair until unit turnaround. Leaks 

detected by BAAQMD repaired within 24 

hours. 

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 > 10K ppm 15 days repair maximum, 

first attempt at repair within 5 days. 

Recordkeeping and Reporting

Submit quarterly reports of non repairable 

components and their leak rates. 

Submit semiannual reports containing the 

number of components, by type, that were 

repaired and for which repair was delayed, 
18 

BAAQMD Reg. 8, Rule 18 40 CFR60 VV, GGG, 40 CFR63 CC 

and the reason for delay. 

Test Methods

U.S. EPA Method 21 for leak screening, 

ASTM Method D86 for VOC content of 

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 handling liquids with an initial 

boiling point greater than 3020

 F. 

Components that present a safety hazard 

Components operating under negative 

pressure or enclosed systems and PRDs 

vented to vapor recovery or disposal system. 

Components handling fluids with less than 

10% by weight VOC. 

Pressure vacuum valves on storage tanks. Components operating under negative 

pressure, pumps with a closed vent system, 

PRDs vented to a control device. 

PRDs installed for thermal protection of 

liquid lines provided they are vented to a 

drain or back in the line 

Administrative requirements for equipment 

handling organic liquids with an initial boiling 

point greater than 3020

 F. 

District Staff Impacts 

Implementation of the proposal will have a negligible impact on the resources of the 

District. Staff will need to review reports regarding mass emission rate determinations 

and, occasionally, conduct site visit to witness of those determinations. 

CONCLUSIONS 

The proposed amendments to Regulation 8, Rule 18, Equipment Leaks will meet the 

commitment made during the adoption of the 2001 Ozone Attainment Plan for Control 

Measure SS-16. The proposal is intended set stringent standard and performance 

requirements that when implemented, will represent the best current industry practices 

and abilities and allow the District to account for any associated emission reduction. 

Pursuant to the Health and Safety Code section 40727, new regulations must meet 

necessity, authority, clarity, consistency, non-duplicity and reference. The proposed 

regulation is: 

• Necessary to protect public health by reducing volatile organic compounds that 

contribute to ozone formation and to carry out the commitment in control measure 
19 

SS-16 in the Bay Area 2001 Ozone Attainment Plan; and to protect public health 

by reducing exposures to toxic air contaminants. 

• Authorized by California Health and Safety Code section 40702. 

• Clear, in that the new regulation specifically delineates the affected industry, 

compliance options and administrative requirements for industry subject to this 

rule. 

• Consistent with other District rules, and not in conflict with state or federal law. 

• Non-duplicative of other statutes, rules or regulations. 

• The proposed regulation properly references the applicable District rules and test 

methods and does not reference other existing law. 

The proposal has met all legal noticing requirements and has been discussed with all 

interested parties. District staff recommends adoption of Regulation 8, Rule 18, 

Equipment Leaks. 

Appendix A 

Comparison of the Basic Provisions of the Fugitive 

Emissions Rules of Four California Air Districts 

Comparison of the Basic Provisions of the Fugitive 

Emissions Rules of Four California Air Districts 

BAAQMD 

Rule 8-18 

South Coast 

AQMD 

Rule 1173 

SJVUAPCD 

Rules 4451 & 

4452 

Ventura Co. 

APCD 

Rule 74.7 

Minimum Leak 

Limits 

ßß8-18-211, 

301!305 

ß1173 (d)(1) ß4451.3.9.1.1; 

ß4451.3.9.2; 

ß4452.3.6.1 

ßß74-7 

L.18!L.20, 

L.22 & L.23, 

Liquid 3 drops/min 3 drops/min 3 drops/min minor >3 

drops/min 

major = stream 

or mist 

Valves 100 ppm HL > 500; LL > 

50k/10k* 

10,000 ppm 

Connections 100 ppm HL > 500; LL > 

50k/10k* 

10,000 ppm 

Pumps/ Compressors 500 ppm HL > 500/100*; LL > 

50k/10k* 

10,000 ppm 

 minor >1,000 

1,000 > major >

10k 

PRDs/PRVs 500 ppm LL > 50k/200* 10,000 ppm major > 200 

ppm 

 L = leak (in ppm or 

drops/min) 

HL = heavy liquid 

leak 

LL = light 

liquid/gas/vapor leak 

*Limits for leaks 

found above leak 

thresholds (see 

Turnaround Lists) 

 

INSPECTION 

FREQUENCIES 

ßß8-18-

401.1!401.3 

ßß1173 (f)(1)(B) & 

(C) 

ß4451.5.2 & 

ß4452.5.1 

ß74-7 D.1 & 

D.2 

Valves Quarterly Quarterly Quarterly Monthly 

!Quarterly 

Connections Annually Quarterly Annually Monthly 

!Annually 

Pumps/ Compressors Quarterly Quarterly Quarterly Monthly 

!Quarterly 

PRDs/PRVs Annually Quarterly Quarterly Quarterly 

(≤110 days) 

Inaccessibles Annually Annually Annual or 

shutdowns 

NONREPAIRABLE 

LIST 

ßß8-18-306.2 & 

306.3 

 Leak Thresholds: 

ß1173(d)(1)Table 1 

ß4451.5.2 & 

ß4452.5.1.4 

Duration < 5 yrs. No time limit (∞) Next shutdown none 

Valves 0.5% 1% 0.5% 2% none 

Connections 0% 0% 0.5% 2% none 
BAAQMD 

Rule 8-18 

South Coast 

AQMD 

Rule 1173 

SJVUAPCD 

Rules 4451 & 

4452 

Ventura Co. 

APCD 

Rule 74.7 

Pumps/ Compressors 1% 5% 1% 2% 

Shutdown or one 

year 

none 

PRDs/PRVs 1% 5% 1% 2% 

REPAIR 

SCHEDULES 

ßß8-18-

301!305 

ß1173 (g)(1) Table 2 ß4451.5.3.2 & 

ß4452.5.1.4 

ß74-7 E Table 1 

Valves 24 hr (District)/ 

7 days 

(operator) 

m: 1 yr 

M: 15 days reduce 

< 10 d/min / 10k 

or vent to flare or 

control or show 

control is 

infeasible 

m: 14 days, M: 

5 days, 

S: 1 days 

Connections 24 hr (District)/ 

7 days 

(operator) 

m: 1 yr 

M: 15 days reduce 

< 10 d/min / 10k 

or vent to flare or 

control or show 

control is 

infeasible 

m: 14 days, M: 

5 days, 

S: 1 days 

Pumps/ Compressors 24 hr (District)/ 

7 days 

(operator) 

500 < LL < 10k: 7 

days 

100 < HL< 500: 7 

days 

3 drops/min & 100 < 

HL < 500: 7 days 

10k < L < 25k: 2 

days/ext 3 days 

L > 25k: 1 day 

HL > 500: 1 day/ext 3 

days 

LL > 3 drops/min: I 

day 

15 day 

> 15 day: replace, 

vent to control or 

repair at shutdown 

m: 14 days, M: 

5 days, 

S: 1 days 

PRDs/PRVs 7 days 

(District)/ 

17 days 

(operator) 

200 < L ≤ 25k: 2 days m: 1 yr 

M: 15 days reduce 

< 10 d/min / 10k 

or vent to flare or 

control or show 

control is 

infeasible 

m: 14 days, M: 

5 days, 

S: 1 days 

 L = leak (in ppm or 

drops) 

HL = heavy liquid 

leak 

LL = light 

liquid/gas/vapor leak 

ext = extended repair 

period 

Leak: m< 10 

drops/min or 

10,000 ppm 

M > 9 drops/min 

or 10,000 ppm. 

Leaks: m≤

10,000, 

10,000 <M ≤

25,000 

S >25,000
Appendix B 

Emissions Estimates 

EMISSION ESTIMATES FOR VALVES 

Valves 

200,000 valves at a Leak Rate 0.5 percent 

Screening Value 

(ppm) 

Numbers of 

Valves 

Leak Rate 

(lb/day) 

 

0 198,575 82 

0<S<100 425 1 

100<S<10,000 850 16 

>10,000 150 507 

Total 606 

Valves 

200,000 valves at a Leak Rate 0.3% with only 0.025% of the valves above the 

10,000-ppm limit

Screening Value 

(ppm) 

Numbers of 

Valves 

Leak Rate 

(lb/day) 

 

0 199,145 82 

0<S<100 255 0 

100<S<10,000 550 10 

>10,000 50 168 

Total 260 

Emission Reduction: 

Emission Reductions 

@ 0.3 percent Leaking 

Emission Reductions 

@ 0.2 percent Leaking 

346 lbs/day 458 lbs/day 

0.21 TPD 0.23 TPD 
Approach and Assumptions 

Source of Emission Factors: 

Emission estimates were calculated using the ARBís "California Implementation 

Guidelines for Estimating Mass Emissions of Fugitive Hydrocarbon Leaks at Petroleum 

Facilities.î 

Number of Values at Refineries: 

The number of valves in currently in operation at all the five Bay Area refineries is 

estimated to 200,000 and is based on WSPA Evaluation of Regulation 8, Rules 8 and 25 

conducted by Radian (December 1996), which estimated 180,000 valves. 

Number of Value Leaking in Excess of 10,000 ppm: 

Based on data collected during inspection audits of refinery fugitive components 

(July 1999 BAAQMD Inspection Audit of Fugitive Components at Refineries and May 

1997 BAAQMD Inspection Audit of Fugitive Components at Refineries), staff estimated 

that 15 percent of the leaking valves leak above 10,000. 

Additional Assumptions for Emission Estimates: 

For valves with leak concentrations between 0 and 100 ppm, the average leak 

concentration is 30 ppm; and the percent of leaking valves between 0 and 100 ppm is 0.5 

times the number of valves leaking below 10,000 ppm. 
Appendix C 

CEQA Analysis 

Appendix D 

Socioeconomic Analysis