SJVUAPCD    

RULE 4401 STEAM-ENHANCED CRUDE OIL PRODUCTION WELLS (Adopted April

11, 1991; Amended September 19, 1991; Amended Decem ber 17, 1992; Amended January 15, 1998; Amended December 14, 2006 , Amended June 16, 2011)

1.0 Purpose

The purpose of this rule is to limit the Volatile O rganic Compound (VOC) emissions from steam-enhanced crude oil production wells.

2.0 Applicability

This rule is applicable to all steam-enhanced crude oil production wells and any associated VOC collection and control systems.

3.0 Definitions

3.1 Air Pollution Control Officer (APCO): as define d in Rule 1020 (Definitions).

3.2 Background: a reading on a portable hydrocarbo n detection instrument which is determined at a distance no greater than two (2) me ters upwind from any component to be inspected and which is not influenc ed by any specific emission point.

3.3 Component: includes, but is not limited to, an y valve, fitting, threaded connection, pump, compressor, pressure relief devic e, pipe, flange, process drain, sealing mechanism, hatch, sight-glass, meter , or seal fluid system in VOC

service.

3.4 Component Type: includes, but is not limited t o, any one (1) of the following groups: valves, fittings, threaded connections, pum ps, compressors, pressure relief devices, pipes, flanges, process drains, sea ling mechanisms, hatches, sight-glasses, meters, or seal fluid systems in VOC service.

3.5 Compressor: a device used to compress gases or vapors or a combination of gases and vapors by the addition of energy, and inc ludes all associated components used for connecting and sealing purposes . The phrase "all associated components used for connecting and seali ng purposes" means the first VOC leak points (first components) connected on the body of the compressor. For example, a valve that is connected to a threade d hole on the body of the compressor, the first VOC leak point is the threade d connection on the body side of the compressor, but the valve itself is not a "first VOC leak point". Similarly, a compressor shaft seal is considered as a “first VOC leak point”.SJVUAPCD    

3.6 Critical Component: a component that would req uire the shutdown of a critical process unit if that component was shut down or dis abled.

3.7 Critical Process Unit: a process unit that mus t remain in service because of its importance to the overall process that requires it to continue to operate, and has no equivalent equipment to replace it or cannot be byp assed, and it is technically infeasible to repair leaks from that process unit w ithout shutting it down and opening the process unit to the atmosphere.

3.8 Critical Process Unit Shutdown: the shutdown of a critical process unit or part of the critical process unit that causes the entire un it to cease operating.

3.9 Cyclic Well: for purposes of this rule, a crud e oil production well, which is periodically (at least once in the preceding two (2 ) year period) injected with steam from any source for the purpose of enhancing oil production.

3.10 District: San Joaquin Valley Unified Air Poll ution Control District, or any person designated to act on its behalf.

3.11 EPA: United States Environmental Protection A gency, or any person designated

to act on its behalf.

3.12 Essential Component: a component that cannot be taken out of service without reducing, by more than 33 percent, the throughput o f the process unit that it

serves.

3.13 Facility: a stationary source as defined in R ule 2201 (New and Modified Stationary Source Rule).

3.14 Fitting: a component, excluding flanges and t hreaded connectors, used to attach or connect pipes or piping system. Examples of a “ fitting” include, but are not limited to quick-disconnect fittings, push-in-fitti ngs, and cam-locks.

3.15 Front Line Production Equipment: a tank or ve ssel in which any organic liquid is placed, held, or stored and that is the first ve ssel that receives crude oil/fluids directly from wells subject to this rule including, but is not limited to, wash tanks, free water knockouts, separators, etc., and that is operating under atmospheric or near atmospheric pressure. After pr oduction is routed through at least one of such tanks or vessels, downstream vess els are no longer considered front line production equipment. A gauge tank, as defined in Section 3.0 of this rule, shall not be considered as Front Line Product ion Equipment.

3.16 Fuel Burning Equipment: as defined in Rule 10 20 (Definitions).SJVUAPCD   	 

3.17 Gauge Tank: for the purposes of this rule onl y, a tank which is used exclusively for measuring the amount of produced fluid produced by an oil well(s) and meets all the following conditions:

3.17.1 Has a capacity of 100 barrels (4,200 gallons ) or less,

3.17.2 Is in operation on or before December 14, 20 06,

3.17.3 Receives or stores produced fluid (crude oil or mixture of crude oil and water),

3.17.4 Is connected to at least one steam-enhanced crude oil production well with a closed vent,

3.17.5 Is upstream of all front line production equ ipment,

3.17.6 Does not have its VOC emissions controlled t o at least 99%, and

3.17.7 The true vapor pressure (TVP) of the produce d fluid in the gauge tank, at all times, shall be less than 0.5 psia as determ ined pursuant to the provisions of Section 6.2.3.

3.18 Inaccessible Component: a component that is l ocated more than 15 feet above ground when access is required from the ground; or a component that is located more than six (6) feet away from a platform when ac cess is required from the platform, or a component in a location that would r equire the elevation of monitoring personnel higher than six (6) feet above permanent support surfaces.

3.19 Inspection: checking and/or testing in order to detect leaks.

3.19.1 District Inspection: inspection of componen ts by District personnel or their representative to insure facilities and/or op erators are in compliance with District requirements.

3.19.2 Operator Inspection: inspection of componen ts conducted by the operator pursuant to the inspection and re-inspection schedu les specified in this rule for the purpose of demonstrating compliance wi th this rule.

3.20 Leak: The dripping of VOC-containing liquid o r the detection of a concentration of total organic compound, above background, determ ined according to the test method specified in Section 6.3.3 that exceeds any of the values specified in Table 1, Section 3.20.1 and Section 3.20.2 of this rule. Any liquid or gas coming from a component undergoing repair or replacement, or du ring sampling of process fluid from a component into a container is not cons idered a leak provided suchSJVUAPCD     activities are done as expeditiously as possible an d with minimal spillage of material and VOC emissions to the atmosphere.

Table 1 Gas Lean in ppmv as Methane Type of Component Major Gas Leak Minor Gas Leak
1. PRDs Greater than 10,000 400 to 10,000
2. Components other than PRDs Greater than 10,000 2 ,000 to 10,000

3.20.1 Major Liquid Leak: a visible mist or a cont inuous flow of liquid that

is not seal lubricant.

3.20.2 Minor Liquid Leak: a liquid leak, except se al lubricant, that is not a major liquid leak and drips liquid at a rate of mor e than three drops per

minute.

3.21 Leak Minimization: reducing a leak to the low est achievable level without damaging the component using best modern practices which include, but are not limited to, adding sealing material to the componen t, tightening the component, or adjusting the component without shutdown of the process that the component serves and that can be safely accommodated.

3.22 Major Component: a pump five (5) brake horsep ower or larger, any compressor, or any pressure relief valve four (4) inches in dia meter or larger.

3.23 Open-ended Line or Valve: a line or valve, ex cept PRD, having one side of the line or valve seat in contact with the process flui d and one side open to the atmosphere, either directly or through an open pipi ng.

3.24 Operate: to perform any activity with, or on any steam-enhanced crude oil production well, including but not limited to produ cing, steam-enhancing, venting, maintaining or repairing.

3.25 Pilot Testing: testing of a new cyclic well f or up to 180 days from each production zone for the purpose of determining the viability of developing a steam-enhanced production zone.

3.26 Portable Hydrocarbon Detection Instrument: a hand-held hydrocarbon analyzer that meets the criteria specified in EPA Method 21, 40 CFR Part 60. The

instrument shall be calibrated on methane.

3.27 Pressure Relief Device (PRD): a pressure reli ef valve or a rupture disk.

3.28 Pressure Relief Valve (PRV): an automatic pre ssure-relieving device associated with a process vessel or piping system that is acti vated by pressure upstream of the device and relieves to the atmosphere (atmosphe ric PRV).SJVUAPCD   
 

3.29 Process Drain: an open portion of a non-conti nuous piping system, including open origination portion(s) of such a system used f or collection and transport of liquids discharged from process vessels, spills, or other sources. Drain origination points and drain termination points are not open-ended lines. Process drains are not open-ended lines.

3.30 Process System: an APCO-approved system that is not open to the atmosphere and is composed of hard-piping, ductwork connection s and, if necessary, flow inducing devices that transport gases or vapors fro m a piece of equipment to a process stream, fuel gas system, sales gas system o r an injection well approved by the Department of Oil, Gas, and Geothermal Resou rces (DOGGR).

3.31 Process Unit: a manufacturing process which i s independent of other processes and is continuous when supplied with a constant fee d of raw material and sufficient storage facilities for the final product

.

3.32 Production Zone: a subsurface geologic format ion or group of formations of oilbearing material through which steam could migrate from a steam injection well, or cyclic well being steamed to an oil production w ell.

3.33 Pump: a device used to transport fluids by th e addition of energy, and includes all associated components used for connecting or sealin g purposes. The phrase "all associated components used for connecting and seali ng purposes" means the first VOC leak points (first components) on the body of t he pump. For example, a

valve that is connected to a threaded hole on the b ody of the pump, the first VOC leak point is the threaded connection on the bo dy side of the pump, but the valve itself is not a "first VOC leak point". Simi larly, a pump shaft seal is considered as a “first VOC leak point”.

3.34 Release: a VOC emission to the atmosphere fro m a PRD caused by an increase in upstream pressure. A leak caused by improper re seating of the PRD is not a

release.

3.35 Rupture Disk: a rigid diaphragm held between flanges for the purpose of isolating organic compounds from the atmosphere or from a dow nstream pressure relief valve. Rupture disks are designed to fail at a cer tain pressure point.

3.36 Service or Repair: a well shall be considered under service or repair during rigup, operation, and rig-down of any rig or pulling u nit used to repair or maintain surface or downhole well equipment.

3.37 Sight glass: a device located on a fluid line or a process vessel that allows an operator to view the product or material inside a f luid line or a process vessel.SJVUAPCD    

3.38 Small Producer: a person who produces a month ly average of less than 6,000 barrels of crude oil per day from all operations in any one county within the District, and who does not engage in refining, tran sporting, or marketing of refined petroleum products. An operator shall qual ify as a small producer only in the county where the operator’s crude oil productio n does not exceed the threshold specified above.

3.39 Steam Drive Well: a crude oil production well which produces from the same production zone in which a steam injection well is completed and is within:

3.39.1 250 feet of a steam injection well, if the i njection well is within a production well pattern of two and one-half (2 1/2) acres or smaller, or

3.39.2 350 feet of a steam injection well, if the i njection well is within a production well pattern of greater than two and one -half (2 1/2) acres but less than or equal to five (5) acres, or

3.39.3 500 feet of a steam injection well, if the i njection well is within a production well pattern larger than five (5) acres, or

3.39.4 1000 feet of a steam injection well, and res ponds to steam injected in an irregular production well pattern, and exhibits any visible emissions.

3.40 Steam-Enhanced Crude Oil Production Well: a s team drive well, cyclic well, or any other well in which the temperature of crude oi l is raised, by the injection of steam, above the production zone temperature that e xisted prior to the injection of

steam.

3.41 Steam Injection Well: a well into which steam is injected that enhances the production of oil from other wells in the same prod uction zone. Cyclic wells which enhance production of oil from other wells in the production zone are considered injection wells.

3.42 Tag: a piece of paper, metal, plastic or othe r suitable material that is attached to a component for the purpose of identification or othe r information.

3.43 True Vapor Pressure (TVP): as defined in Rule 4623 (Storage of Organic Liquids).

3.44 Turnaround: a scheduled shutdown of a process unit for maintenance and repair

work.

3.45 Unsafe-to-Monitor Component: a component inst alled at a location that would prevent the safe inspection or repair of a componen t as defined by OSHA standards or in provisions for worker safety stated in 29 CFR 1910.SJVUAPCD    

3.46 Vacuum Service: operating under a negative ga uge pressure or below atmospheric pressure.

3.47 Valve: a device that regulates the flow of fl uid in a piping system by means of an external actuator acting to permit or block pass age of fluid.

3.48 Visible Emissions: from well vents, visible e missions are any visible plume including water vapor. When the ambient air temper ature is 60 o F or less a well

vent shall be considered to have visible emissions if there is any visible plume and

there is a leak as defined above.

3.49 Volatile Organic Compound (VOC): as defined i n Rule 1020 (Definitions).

3.50 VOC Collection and Control System: an APCO-ap proved system that is not open to the atmosphere and that is composed of hard-pipi ng, ductwork connections and, if necessary, flow inducing devices that transport gas or vapor from a piece or pieces of equipment to an APCO-approved control dev ice that has a VOC destruction or removal efficiency of at least 99%, or that transports gases or vapors back to a process system.

3.51 VOC Emissions: emissions resulting from the o peration of a steam-enhanced crude oil production well. Such emissions include uncondensed casing vent emissions and any emissions resulting from the hand ling, transfer, storage, or disposal of condensed and uncondensed casing vapors

.

3.52 Well Stimulation: cyclic steam injection of a well for up to 180 days prior to the well being placed in service as a continuous steam injection well.

3.53 Well Vent: an opening on a well head that faci litates or blocks the flow of well casing vapors to the atmosphere or to a VOC collect ion and control system.

4.0 Exemptions

4.1 Any steam-enhanced crude oil production well un dergoing service or repair during the time the well is not producing.

4.2 The requirements of this rule for cyclic wells shall not apply to up to 40 wells owned by a company and undergoing pilot testing pro vided;

4.2.1 the production zone on that property has not been injected with steam during the preceding two (2) years,

4.2.2 the well is located more than 1000 feet from an existing well vent vapor collection and control system operated by the compa ny, andSJVUAPCD     4.2.3 the operation is under District permit.

4.3 The requirements of this rule shall not apply t o up to 40 cyclic wells owned by a company and undergoing well stimulation, provided;

4.3.1 the well is located more than 1000 feet from an existing well vent vapor collection and control system operated by the compa ny, and

4.3.2 the operation is under District permit.

4.4 The requirements of this rule shall not apply to up to five (5) cyclic wells owned by a company that is not a small producer, in each stationary source as defined in Rule 2201 (New and Modified Stationary Source Revie w Rule), and up to 20 cyclic wells owned by a small producer, provided th e requirements of Section

4.4.1 and Section 4.4.2 are met.

4.4.1 the well is located more than 1000 feet from an existing well vent vapor control system operated by the company, and

4.4.2 the operation is under District permit.

4.5 The requirements of this rule shall not apply t o components serving the produced fluid line.

4.6 Except for complying with the applicable requir ements of Section 6.1, Section 6.6.6 and Section 7.2, the requirements of this rul e shall not apply to components described in Section 4.6.1 through Secti on 4.6.4. An operator claiming an exemption pursuant to Section 4.6 shall provide proof of the applicable criteria to the satisfaction of the APCO

.

4.6.1 Pressure relief devices, pumps, and compresso rs that are enclosed and whose emissions are controlled with an operating VO C collection and control system as defined in Section 3.0.

4.6.2 Components buried below ground.

4.6.3 Components used exclusively in vacuum service

.

4.6.4 One-half inch nominal or less stainless steel tube fittings which have been

demonstrated to the APCO to be leak-free based on i nitial inspection using the test method specified in Section 6.3.3.SJVUAPCD   
 

4.7 The requirements of Section 5.4.1 through Secti on 5.4.7 of this rule shall not apply to components exclusively handling gas/vapor or liquid with a VOC content of ten percent by weight or less ( ≤ 10 wt.%), as determined by the test

methods in Section 6.3.4.

5.0 Requirements

5.1 An operator shall not operate a steam-enhanced crude oil production well unless the operator complies with the requirements of eith er Section 5.1.1 or Section

5.1.2.

5.1.1 The steam-enhanced crude oil production well vent is closed and the front line production equipment downstream of the w ells that carry produced fluids (crude oil or mixture of crude oil and water) is connected to a VOC collection and control system as defined in Section 3.0. The well vent may be temporarily opened durin g periods of attended service or repair of the well provided suc h activity is done as expeditiously as possible with minimal spillage of material and VOC emissions to the atmosphere.

5.1.2 The steam-enhanced crude oil production well vent is open and the well

vent is connected to a VOC collection and control s ystem as defined in

Section 3.0.

5.2 Determination of Compliance with the Leak Stand ards

5.2.1 An operator shall be in violation of this rul e if any District inspection

demonstrates that one or more of the conditions in Section 5.2.2 exist at the facility or if any operator inspection conducte d pursuant to Section 5.4

demonstrates that one or more of the conditions in Section 5.2.2 exist at the facility.

5.2.2 Leak Standards

The following conditions shall be used for determin ation of violation during an inspection pursuant to the provisions of Section 5.2.1.

5.2.2.1 Existence of an open-ended line or a valve located at the end of the line that is not sealed with a blind flange, pl ug, cap, or a second closed valve that is not closed at all times , except during attended operations requiring process fluid flow th rough the open-ended lines. Attended operations include drai ning or degassing operations, connection of temporary proce ss equipment, sampling of process streams, emergency v enting, and other normal operational needs, provided such o perationsSJVUAPCD    are done as expeditiously as possible and with mini mal spillage of material and VOC emissions to the atmosphere.

5.2.2.2 Existence of a component with a major liqui d leak as defined in

Section 3.0.

5.2.2.3 Existence of a component with a gas leak gr eater than 50,000

ppmv.

5.2.2.4 Existence of a component leak described in Section 5.2.2.4.1 through Section 5.2.2.4.3 in excess of the allowabl e number of leaks specified in Table 2.

5.2.2.4.1 A minor liquid leak, or

5.2.2.4.2 A minor gas leak, or

5.2.2.4.3 A gas leak greater than 10,000 ppmv up to 50,000

ppmv.

Table 2 Number of Allowable Leaks

Number of Steam-Enhanced Crude Oil

Production Wells Connected to a VOC Collection and Control System Number of Allowable Leaks

1 to 25 3

26 to 50 6

51 to 100 8

101 to 250 10

251 to 500 15

More than 500 One (1) for each 20 wells

tested with a minimum of 50

wells tested.

5.3 An operator shall comply with the following op erating requirements:

5.3.1 An operator shall not use any component with a leak as defined in Section 3.0, or that is found to be in violation of the pro visions of Section 5.2.2. However, components that were found leaking may be used provided such leaking components have been identified with a tag for repair, are repaired, or awaiting re-inspection after being rep aired within the applicable time frame specified in Section 5.5 of t his rule.SJVUAPCD     5.3.2 Each hatch shall be closed at all times excep t during sampling or adding of process material through the hatch, or during at tended repair, replacement, or maintenance operations, provided su ch activities are done as expeditiously as possible with minimal spil lage of material and VOC emissions to the atmosphere.

5.3.3 An operator shall comply with the requirement s of Section 6.7 if there is any change in the description of major components o r critical components.

5.4 Inspection and Re-inspection Requirements

Unless otherwise specified, an operator shall perfo rm all component inspections and gas leak measurements pursuant to the requireme nts of Section 6.3.3.

5.4.1 Except for pipes and unsafe-to-monitor compon ents, an operator shall inspect all other components pursuant to the requir ements of Section 6.3.3 at least once every year.

5.4.2 An operator shall visually inspect all pipes at least once every year. Any visual inspection of pipes that indicates a leak th at cannot be immediately repaired to meet the leak standards of this rule sh all be inspected within 24 hours after detecting the leak. If a leak is found , the leak shall be repaired as soon as practicable but not later than the time frame specified in Table 3

of this rule.

5.4.3 In addition to the inspections required by S ection 5.4.1, an operator shall inspect for leaks all accessible operating pumps, c ompressors, and PRDs

in service as follows:

5.4.3.1 An operator shall audio-visually (by hearin g and by sight) inspect for leaks all accessible operating pumps, c ompressors, and PRDs in service at least once each calendar wee k.

5.4.3.2 Any audio-visual inspection of an accessibl e operating pump, compressor, and PRD performed by an operator that i ndicates a leak that cannot be immediately repaired to meet th e leak standards of this rule shall be inspected not later than 24 hours after conducting the audio-visual inspection. If a leak is found, the leak shall be repaired as soon as practicable b ut not later than the time frame specified in Table 3 of this ru le.

5.4.4 In addition to the inspections required by Se ction 5.4.1, Section 5.4.2 and Section 5.4.3, an operator shall perform the follow ing inspections:SJVUAPCD     5.4.4.1 An operator shall initially inspect a PRD t hat releases to the atmosphere as soon as practicable but not later tha n 24 hours after the discovery of the release. An operator sh all re-inspect

the PRD not earlier than 24 hours after the initial inspection but not later than 15 calendar days after the initial i nspection.

5.4.4.2 An operator shall inspect all new, replaced , or repaired fittings, flanges, and threaded connections within 72 hours o f placing the component in service.

5.4.4.3 Except for PRDs subject to the requirements of Section 5.4.4.1, an operator shall inspect a component that has been repaired or replaced not later than 15 calendar days after the component was repaired or replaced.

5.4.7 An operator shall inspect all unsafe-to-monit or components during each

turnaround.

5.4.8 A District inspection in no way fulfills any of the mandatory inspection requirements that are placed upon operators and can not be used or counted as an inspection required of an operator.

5.5 Leak Repair Requirements

5.5.1 An operator shall affix a readily visible wea therproof tag to a leaking component upon detection of the leak. An operator shall include the following information on the tag:

5.5.1.1 The date and time of leak detection.

5.5.1.2 The date and time of leak measurement.

5.5.1.3 For a gaseous leak, the leak concentration in ppmv.

5.5.1.4 For a liquid leak, whether it is a major li quid leak or a minor liquid leak.

5.5.1.5 Whether the component is an essential compo nent, an unsafe-tomonitor component, or a critical component.

5.5.2 An operator shall keep the tag affixed to the component until an operator has met all of the following conditions:

5.5.2.1 Repaired or replaced the leaking component, andSJVUAPCD   	  5.5.2.2 Re-inspected the component using the test m ethod in Section 6.3.3, and

5.5.2.3 The component is found to be in compliance with the requirements of this rule.

5.5.3 An operator shall minimize a component leak i n order to stop or reduce leakage to the atmosphere immediately to the extent possible, but not later than one (1) hour after detection of the leak.

5.5.4 Except for leaking critical components or lea king essential components subject to the requirements of Section 5.5.7, if an operator has minimized a leak but the leak still exceeds the applicable le ak limits as defined in Section 3.0, an operator shall comply with at least one of the requirements of Section 5.5.4.1, Section 5.5.4.2, or Section 5.5 .4.3 as soon as practicable but not later than the time period spec ified in Table 3.

5.5.4.1 Repair or replace the leaking component; or

5.5.4.2 Vent the leaking component to a VOC collect ion and control system as defined in Section 3.0, or

5.5.4.3 Remove the leaking component from operation

.

 	   Type of Leak Repair Period in Calendar Days

Gas Leaks

Minor Gas Leak 14

Major Gas Leak less than or equal to 50,000 ppmv 5

Gas Leak greater than 50,000 ppmv 2

Liquid Leaks

Minor Liquid Leak 3

Major Liquid Leak 2

5.5.5 The leak rate measured after leak minimizatio n has been performed shall be the leak rate used to determine the applicable r epair period specified in

Table 3.

5.5.6 The time of the initial leak detection shall be the start of the repair period specified in Table 3.SJVUAPCD     5.5.7 If the leaking component is an essential comp onent or a critical component that cannot be immediately shut down for repairs, and if the

leak has been minimized but the leak still exceeds the applicable leak standard of this rule, the operator shall repair or replace the essential component or critical component to eliminate the le ak during the next process unit turnaround, but in no case later than one year from the date of the original leak detection, whichever comes earlie r.

6.0 Administrative Requirements

6.1 Recordkeeping and Submissions

An operator shall maintain the records required by Section 6.1 and Section 6.2 for a period of five (5) years. These records shall be made available to the APCO, California Air Resources Board (ARB), and EPA upon request.

6.1.1 The operator of any steam-enhanced crude oil production well shall

maintain records of the date and well identificatio n where steam injection

or well stimulation occurs.

6.1.2 A small producer shall maintain monthly recor ds of county-specific crude oil production. For the purpose of this rule, the monthly crude oil production records required by the California Divis ion of Oil, Gas, and Geothermal Resources may be used to satisfy Section 6.1.2.

6.1.3 An operator of any steam-enhanced crude oil p roduction well shall keep source test records which demonstrate compliance wi th the control efficiency requirements of the VOC collection and c ontrol system as

defined in Section 3.0.

6.1.4 The inspection log maintained pursuant to Sec tion 6.4.

6.1.5 Records of each calibration of the portable hydrocarbon detection instrument utilized for inspecting components, incl uding a copy of current calibration gas certification from the vendor of sa id calibration gas cylinder, the date of calibration, concentration of calibration gas, instrument reading of calibration gas before adjust ment, instrument reading of calibration gas after adjustment, calibr ation gas expiration date, and calibration gas cylinder pressure at the time o f calibration.

6.1.6 An operator shall maintain copies at the fac ility of the training records of the training program operated pursuant to Section 6 .5.

6.1.7 An operator shall keep a copy of the APCO-ap proved Operator Management Plan at the facility.SJVUAPCD   
  6.1.8 An operator shall keep a list of all gauge t anks, as defined in Section 3.0. The list shall contain the size, identification nu mber, the location of each gauge tank and specify whether the gauge tank is upstream of all front line production equipment.

6.1.9 The results of gauge tank TVP testing conduct ed pursuant to Section 6.2.3 shall be submitted to the APCO within 60 days after the completion of the testing.

6.1.10 An operator that discovers that a PRD has re leased shall record the date that the release was discovered, and the identity a nd location of the PRD that released. An operator shall submit such infor mation recorded during the calendar year of the release to the APCO no later than 60 days after the end of the calendar year.

6.2 Compliance Source Testing

6.2.1 An operator shall source test annually all VO C collection and control systems used to control emissions from steam-enhanc ed crude oil production well vents to determine the control effi ciency of the device(s) used for destruction or removal of VOC. Compliance testing shall be performed annually by source testers certified by A RB. Testing shall be performed during June, July, August, or September o f each year if the system's control efficiency is dependent upon ambie nt air temperature. A process system is not subject to compliance source testing requirements.

6.2.2 If approved by the APCO, a VOC collection and control system is not subject to Section 6.2.1 if all uncondensed VOC emi ssions collected by the system are controlled by a device meeting one of th e requirements in Sections 6.2.2.1 through 6.2.2.3.

6.2.2.1 An internal combustion engine subject to Di strict Rule 4702

(Internal Combustion Engines – Phase 2); or

6.2.2.2 A combustion device subject to District Rul e 4320 (Advanced

Emission Reduction Options for Boilers, Steam Gener ators, and Process Heaters Greater than 5.0 MMBtu/hr); Dis trict Rule 4307 (Boilers, Steam Generators, and Process Heater s – 2.0 MMBtu/hr to 5.0 MMBtu/hr); or District Rule 4308 (B oilers, Steam Generators, and Process Heaters – 0.075 MMBtu /hr to 2.0 MMBtu/hr); or

6.2.2.3 A unit subject to District Rule 4311 (Flare s).SJVUAPCD     6.2.3 An operator shall comply with the following r equirements for each gauge tank, as defined in Section 3.0:

6.2.3.1 An operator shall conduct periodic TVP test ing of each gauge tank at least once every 24 months during summer (J uly – September), and whenever there is a change in the s ource or type of produced fluid in the gauge tank.

6.2.3.2 The TVP testing shall be conducted at the a ctual storage temperature of the produced fluid in the gauge tank using the applicable TVP test method specified in Section 6.4 of Rule 4623 (Storage of Organic Liquids). The operator sh all submit the TVP testing results to the APCO as specified in Section

6.1.9.

6.3 Test Methods

Test methods that are equivalent to those test meth ods specified in Section 6.3.1 through Section 6.3.4 may be used provided that suc h equivalent test methods have been previously approved, in writing, by the E PA, ARB, and the APCO.

6.3.1 The control efficiency of any VOC control dev ice, measured and calculated as carbon, shall be determined by EPA Me thod 25, except when the outlet concentration must be below 50 ppm in order to meet the standard, in which case EPA Method 25a may be used. EPA Method 18 may be used in lieu of EPA Method 25 or EPA Method 25a provided the identity and approximate concentrations of the anal ytes/compounds in the sample gas stream are known before analysis with th e gas chromatograph and the gas chromatograph is calibrated for each of those known analyte/compound to ensure that the VOC concentrati ons are neither under- or over-reported.

6.3.2 VOC content shall be analyzed by using the la test revision of ASTM Method E168, E169, or E260 as applicable. Analysis of halogenated exempt compounds shall be performed by using ARB Me thod 432.

6.3.3 Leak inspection, other than audio-visual, and measurements of gaseous leak concentrations shall be conducted according to EPA Method 21 using an appropriate portable hydrocarbon detection instr ument calibrated with

methane. The instrument shall be calibrated in acc ordance with the procedures specified in EPA Method 21 or the manufa cturer’s instruction, as appropriate, not more than 30 days prior to its use. The operator shall

record the calibration date of the instrument. Whe re safety is a concern, such as measuring leaks from compressor seals or pu mp seals when the shaft is rotating, a person shall measure leaks by placing the instrumentSJVUAPCD     probe inlet at a distance of one (1) centimeter or less from the surface of the component interface.

6.3.4 The VOC content by weight percent (wt.%) shal l be determined using American Society of Testing and Materials (ASTM) D1 945 for gases and South Coast Air Quality Management District (SCAQMD ) Method 304-91 or the latest revision of ASTM Method E168, E169 or E260 for liquids.

6.4 Inspection Log

An operator shall maintain an inspection log in whi ch an operator records, at a minimum, all of the following information for each inspection performed:

6.4.1 The total number of components inspected, and the total number and percentage of leaking components found by component type.

6.4.2 The location, type, and name or description o f each leaking component and description of any unit where the leaking compo nent is found.

6.4.3 The date of leak detection and the method of leak detection.

6.4.4 For gaseous leaks, the leak concentration in ppmv, and for liquid leaks record whether the leak is a major liquid leak or a minor liquid leak.

6.4.5 The date of repair, replacement, or removal f rom operation of leaking

components.

6.4.6 The identify and location of essential compon ents and critical components found leaking that cannot be repaired until the nex t process unit turnaround or not later than one year after leak detection, wh ichever comes earlier.

6.4.7 The methods used to minimize the leak from es sential components and critical components found leaking that cannot be re paired until the next process unit turnaround or not later than one year after leak detection,

whichever comes earlier.

6.4.8 The date of re-inspection and the leak concen tration in ppmv after the component is repaired or is replaced.

6.4.9 The inspector’s name, business mailing addres s, and business telephone

number.

6.4.10 The date and signature of the facility opera tor responsible for the inspection and repair program certifying the accura cy of the information recorded in the log.SJVUAPCD    

6.5 Employee Training Program

An operator shall establish and implement an employ ee training program for inspecting and repairing components and recordkeepi ng procedures, as necessary.

6.6 Operator Management Plan

By June 30, 2008, an operator whose existing wells are subject to this rule or whose existing wells are exempt pursuant to Section 4.0 of this rule on or before December 14, 2006 shall prepare and submit an Opera tor Management Plan for approval by the APCO. An operator may use diagrams , charts, spreadsheets, or other methods approved by the APCO to describe the information required by Section 6.6.4 through Section 6.6.7 below. The Ope rator Management Plan shall include, at a minimum, all of the following informa tion:

6.6.1 A description of all wells and all associated VOC collection and control systems subject to this rule, and all wells and all associated VOC collection and control systems that are exempt pursuant to Sec tion 4.0 of this rule.

6.6.2 Identification and description of any known h azard that might affect the safety of an inspector.

6.6.3 Except for pipes, the number of components th at are subject to this rule by

component type.

6.6.4 Except for pipes, the number and types of maj or components, inaccessible components, unsafe-to-monitor components, critical components, and essential components that are subject to this rule and the reason(s) for such designation.

6.6.5 Except for pipes, the location of components subject to the rule (components may be grouped together functionally by process unit or facility description).

6.6.6 Except for pipes, components exempt pursuant to Section 4.6 (except for components buried below ground) may be described in the Operator Management Plan by grouping them functionally by pr ocess unit or facility description. The results of any laborator y testing or other pertinent information to demonstrate compliance wit h the applicable exemption criteria for components for which an exem ption is being claimed pursuant to Section 4.6 shall be submitted with the Operator Management Plan.

6.6.7 A detailed schedule of an operator’s inspecti ons of components to be conducted as required by this rule and whether the operator inspections ofSJVUAPCD   
  components required by this rule will be performed by a qualified contractor or by an in-house team.

6.6.8 A description of the training standards for personnel that inspect and repair

components.

6.6.9 A description of the leak detection training for conducting the test method specified in Section 6.3.3 for new operators, and f or experienced

operators, as necessary.

6.7 By January 30 of each year, an operator shall s ubmit to the APCO for approval, in writing, an annual report indicating any changes to an existing Operator Management Plan.

6.8 The APCO shall provide written notice to the op erator of the approval or incompleteness of a new or revised Operator Managem ent Plan within 60 days of receiving such Operator Management Plan. If the AP CO fails to respond in writing within 60 days after the date of receiving the Operator Management Plan, it shall be deemed approved. No provision of the O perator Management Plan, approved or not, shall conflict with or take preced ence over any provision of this

rule.

7.0 Compliance Schedule

7.1 The operator of any new steam-enhanced crude oi l production well, or any nonsteam-enhanced crude oil production well converted to a steam-enhanced crude oil production well shall comply with the requirements of this rule and the applicable permit requirements of Rule 2201 (New and Modified Stationary Source Review Rule) before steam injection and no later than the first detectable flow at the casing vent.

7.2 Steam-enhanced crude oil production wells and compo nents that are exempt pursuant to Section 4.2, 4.3, 4.4, 4.6, or 4.7 that become subject to this rule through loss of exemption status shall not be opera ted until such time that they are in full compliance with the requirements of thi s rule.SJVUAPCD    This page intentionally blank.