Regulation 8 Rule 18: Equipment Leaks - 2024 Amendment (Draft)

Learn about the Air District's development process for amendments to Regulation 8, Rule 18, which would further address emissions from equipment leaks at refineries, chemical plants, bulk terminals and bulk plants, and other facilities that store, transport, and use organic liquids.

Find out about the status of the rule development process. Information on hearings, workshops, and other events is provided below.

The Air District is developing amendments to Rule 8-18 to reduce emissions of Total Organic Compounds (TOC) from equipment leaks at refineries, chemical plants, bulk terminals and bulk plants, and other facilities that store, transport, and use organic liquids. Rule 8-18 was identified as part of the Air District's Expedited Best Available Retrofit Control Technology (BARCT) Implementation Schedule adopted per AB 617. Administrative amendments were made to Rule 8-18 in 2021. However, Rule 8-18 was last substantively amended in December 2015 to include equipment at these facilities that services heavy liquids (liquid with an initial boiling point greater than 302 ºF). Due to questions regarding emissions reductions and cost-effectiveness related to including components in heavy liquid service in monitoring requirements, Resolution No. 2015-12 directed staff to examine these issues further and recommend modifying this rule if appropriate. In addition, the Air District was sued in 2016 by three petroleum refineries challenging the 2015 Amendments, resulting in a settlement agreement between the Air District and the petroleum refineries issued in March 2017.

To determine appropriate emission factors for heavy liquid component leaks, a Heavy Liquids Study was conducted and finalized in April 2022. Using this study, the Air District is currently proceeding with rule amendments to limit emissions associated with a subset of equipment that services heavy liquids.

The Air District has developed draft amendments to Rule 8-18, which include new Leak Detection and Repair (LDAR) and operating requirements for select components in heavy liquid service, more stringent leak standards, enhanced inspection procedures and reporting requirements, and other modifications and administrative updates for clarity and completeness. These rule amendments also include the provisions agreed upon in the settlement agreement. Staff is seeking comments on the draft amendments and a Preliminary Staff Report:

Written and/or email comments on the draft rule amendments and Preliminary Staff Report must be received by 5:00 PM on December 20, 2023. Comments may be submitted to:

Rule Development
Bay Area Air Quality Management District
375 Beale Street, Suite 600
San Francisco, CA 94105
Or via e-mail to

Following this Request for Comments and closing of the public comment period, staff will assess the need for changes to the draft rule amendments. Staff may consider soliciting further input or may proceed to a public hearing before the Air District’s Board of Directors.

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Hearings, Workshops and Other Events

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Last Updated: 3/11/2024