Technical Support Document 

for 

EPA's Notice of Proposed Rulemaking 

on revisions to the 

California State Implementation Plan 

as submitted by the State of California, Air Resources Board 

for the San Joaquin Valley Unified Air Pollution Control District 

 

EPA's Analysis of 

San Joaquin Valley Unified Air Pollution Control District’s 

Rule 4402, Crude Oil Production Sumps 

United States Environmental Protection Agency, Region IX 

Air Division 

 

May 2012 

Prepared by: Nicole Law 

 Reviewed by: Andrew Steckel
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San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) 

Rule 4402, Crude Oil Production Sumps 

I. Chronology of Rule Adoption and Submittal 

April 11, 1991 SJVUAPCD initially adopted Rule 465.2. 

December 17, 1992 SJVUAPCD amended and renumbered Rule 465.2 to 4402. 

December 13, 1994 EPA approved the 1991 version of Rule 465.2 (59 FR 64132) into the 

California State Implementation Plan (SIP). 

August 24, 2007 The California Air Resources Board (ARB) submitted the 1992 amendment 

of Rule 4402. 

July 7, 2011 EPA finalized a limited approval and limited disapproval of the 1992 

amendment of Rule 4402 (76 FR 39777). 

December 15, 2011 SJVUAPCD revised Rule 4402. 

 

February 23, 2012 ARB submitted the 2011 version of Rule 4402 to EPA as a revision to the 

SIP. 

March 13, 2012 EPA found ARB’s 2012 submittal complete. 

Consequently, the 1992 version of Rule 4402 is currently the SIP approved version. 

II. Background

Crude oil production sumps are used to separate useable products from sand, water, and other 

fluids produced from oil wells. They work by gravity separation because of the density 

difference between oil and water. While the separation procedure is different for every producer, 

generally the oil-water mixture collected from wells is placed in a primary sump (or tank) where 

the oil is separated and piped to a separate oil collection/storage tank. The oily-water is then sent 

to a secondary sump where oil is recovered again by gravity separation and separated to the oil 

collection/storage tank. The water may be sent to a tertiary sump where the same process 

occurs: oil is collected and produced water is sent to a collection pond. Oil content, and, 

therefore, volatile organic compound (VOC) emissions, decreases at each subsequent stage in the 

separation process. 

Rule 4402 limits VOC emissions from these operations by requiring tanks in place of primary 

(first stage) production sumps and requiring various controls for secondary and tertiary sumps. 

Emissions from all sumps in the San Joaquin Valley are 968.44 tons VOC per year (2.7 tons per 

day) according to the District’s 2007 Area Source Emission Inventory Methodology. The same 

inventory reports 95 active sumps. A sumps database from the Department of Oil, Gas, and 

Geothermal Resources (DOGGR) reports 120 sumps containing oil and water between the years 
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2009 and 2011, and a CARB 2007 Oil and Gas Industry survey reports 62 sumps in the San 

Joaquin Valley. The District’s 2007 Area Source Emission Inventory reports no active primary 

sumps for heavy or light oil production, 16 light oil sumps, and 79 heavy oil sumps. Of the 16 

light oil sumps, six are second stage sumps and ten are third stage sumps and of the 79 heavy oil 

sumps, 34 are second stage sumps and 45 are third stage sumps. There is possibly one third 

stage heavy oil sump at a large operation; the remaining 94 sumps are located at small 

operations. 

Ponds, as defined in Rule 4402, are very large excavations used for storage and disposal of clean 

produced water. Rule 4402 provides that ponds may contain no more than five percent visible 

oil on the surface area and presumably receive produced water from a tertiary stage sump. 

Appendix B to the District’s Staff Report states there are 74 active ponds in San Joaquin Valley 

and estimates emissions from these ponds to be 8.95 tons VOC per year from the District’s use of 

EPA’s Water9 software. 

III. Summary of Rule & Recent Amendments

SJVUAPCD Rule 4402, Crude Oil Production Sumps, is designed to decrease VOC emissions 

from sumps used in crude oil and water separation by prohibiting first stage sumps and requiring 

control measures such as covers. 

SJVUAPCD amended Rule 4402 on December 15, 2011 to address deficiencies identified by 

EPA in a simultaneous limited approval and limited disapproval published on July 7, 2011. 

The December 15, 2011 amendments include: 

1. The purpose of the rule has been shortened to remove the rule requirements and only include 

the purpose which is to limit VOC emissions from sumps. 

2. New definitions were added for Air Pollution Control Officer (APCO), ARB, EPA, operator, 

and volatile organic compound. 

3. The definition for “clean produced water” was amended to include additional test methods. 

4. The exemption section 4.1.5 was amended to remove “first stage,” as any first stage sumps 

are no longer exempt from the rule. 

5. The exemption section 4.1.7 was amended to remove “pits.” A new exemption section 4.1.8 

was added to continue to include pits, but to additionally require clean-up. 

6. Section 5.0 Requirements, added a new section 5.1 which states, “On and after January 1, 

2013, first stage sumps are prohibited.” This removes any exemptions for all first stage 

sumps. 

7. Throughout the rule in the definitions section, requirements section, and recordkeeping 

section, the term “person” has been replaced with “operator.” 
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8. The language in section 5.4 (formally 5.3) has been changed regarding exemption from Rule 

2201. 

9. Language has been added to section 6.1, Recordkeeping, to require records be kept and 

maintained for a minimum of five years beginning January 1, 2013. 

10. Changes to section 6.1 have been made to clarify what type of information needs to be 

maintained and recorded in order to justify an exemption from rule requirements. 

Information includes API gravity of crude oil, sump surface area, and annual production 

rates. 

11. Section 6.2, Test Methods, has added language to specify the listed test methods are used to 

determine compliance with requirements in section 5.0. 

12. Section 7.0, Compliance Schedule, has been removed as the section is outdated. 

IV. Rule Evaluation Criteria

The following criteria were used to evaluate the submitted rule: 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation Cutpoints, Deficiencies, 

and Deviations, EPA, May 25, 1988), the Little Bluebook (Guidance Document for 

Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001), and 

State Implementation Plans, General Preamble for the Implementation of Title I of the Clean 

Air Amendments of 1990 (57 FR 13498, April 16, 1992) were used to help evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 

2. RACT –Letter from William T. Hartnett to Regional Air Division Directors, “RACT Qs & 

As – Reasonable Available Control Technology (RACT) Questions and Answers,” (May 18, 

2006), and other state and local rules for this category were used to help evaluate the RACT 

requirements of CAA §182(b)(2). 

 

3. SIP Relaxation - We have evaluated this SIP revision to determine whether it would interfere 

with any applicable requirement concerning attainment and reasonable further progress (RFP) 

or any other applicable requirement of the Act (CAA 110(l)) or modify, in a nonattainment 

area, any SIP-approved control requirement in effect before November 15, 1990 (CAA 193). 

V. Evaluation of Enforceability and SIP Relaxation

The July 7, 2011 limited approval and simultaneous limited disapproval of the previous version 

of SJVUAPCD Rule 4402 concluded that the rule fulfilled CAA §110(a)(2)(A) enforceability 

requirements except for a few deficiencies that prevented full approval. A summary of those 

deficiencies and how they are addressed by the revised Rule 4402 submitted in February 2012 is 

provided below: 
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a. Exemptions from the NSR program should not be in source specific prohibitory rules like 

Rule 4402. 

The language regarding the NSR exemption in section 5.4 was amended. The District 

revised the language to say replacement tanks “may” not be considered an emission 

change for Rule 2201. The section now has appropriate language to indicate that 

replacing a unit to comply with the requirements of the rule may be, but not necessarily 

shall be, considered an emission change for the purposes of Rule 2201. This 

determination is properly made by applying the requirements of Rule 2201. 

b. Test methods need to be revised to remove and/or replace inappropriate or outdated test 

methods. 

Test methods were added to the definition of “clean produced water” in section 3.4 and 

test methods section 6.2 was amended to remove inappropriate methods and add correct 

ones. 

c. Changes to the Recordkeeping section need to be made to add additional requirements. 

The District revised Section 6.0 to add new recordkeeping requirements for operators 

claiming exemptions. In particular, Rule 4402 includes new requirements to keep records 

of sump surface area and annual production rates to verify exemptions in section 4.1.1 and 

4.1.3 for small and very small producers. Rule 4402 also includes new requirements to 

verify the exemption in 4.1.8 for the emergency use of pits. The District also revised 

recordkeeping section 6.1 to require records be maintained for a minimum of five years. 

The rule changes summarized above are adequate to address the enforceability deficiencies 

identified previously, and we have identified no additional deficiencies related strictly to 

enforceability. Therefore, we conclude that the recordkeeping and other requirements ensure that 

the submitted rule can be enforced and that the rule is consistent with CAA §110(a)(2)(A). In 

addition, we propose to determine that our approval of the submittal would comply with CAA 

sections 110(l) and 193, because the submitted SIP revision is more stringent than the rule 

previously approved into the SIP and would not interfere with any applicable requirement 

concerning attainment and reasonable further progress (RFP) or any other applicable requirement 

of the Act (CAA 110(l)) or modify, in a nonattainment area, any SIP-approved control 

requirement in effect before November 15, 1990 (CAA 193). 

VI. Evaluation of RACT 

Our limited approval and simultaneous limited disapproval of SJVUAPCD Rule 4402, identified 

several RACT rule deficiencies that prevented full approval.1 A summary of those deficiencies 

 

1 On January 10, 2012, EPA partially approved and partially disapproved SJVUAPCD’s 2009 RACT SIP, based in 

part on our conclusion that the State had not fully satisfied CAA section 182 RACT requirements for production oil 

sumps. 77 FR 1417, 1425. Final approval of Rule 4402 will satisfy California's obligation to implement RACT 

under CAA section 182 for this source category for the 1-hour and 1997 8-hour ozone NAAQS. 
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and how the revised Rule 4402 or additional analysis by the District addresses the deficiencies is 

provided below. 

a. There is no time limit that oil or oil water can be kept in an emergency pit. 

Rule 4402 now has clean-up requirements for emergency pits in section 4.1.8 and 

recordkeeping requirements associated with such pits in section 6.1.7. Clean up 

procedures need to begin 24 hours within the emergency occurrence and need to be 

completed within 15 calendar days. Additionally, date and times of when emergency pit 

usage started, clean up of the emergency pit began, and clean up of the emergency pit 

finished are required to be recorded. This fully addresses the original deficiency 

identified in EPA’s FR notice by requiring clean up beginning within 24 hours of the 

occurrence and completion to occur within 15 days. 

b. Rule 4402 allows first stage sumps. 

Rule 4402 now prohibits first stage sumps beginning in January 1, 2013 in section 5.1. 

This change fully addresses the original deficiency. 

c. There are inadequate VOC controls required for tanks that replace first stage sumps. 

The District explained in the Staff Report that it did not put tank requirements in Rule 

4402 because there is already an existing rule for controlling VOCs from tanks. Staff 

Report at 23. Rule 4623 (Storage of Organic Liquids) controls VOC emissions from 

storage of organic liquids and was SIP approved as meeting RACT on September 13, 

2005. 70 FR 53937. Therefore, we concur with the District that no revision to Rule 4402 

is necessary to address this issue. 

d. Exemptions for ponds of clean produced water are broader than those found in analogous 

rules in other Districts. 

The District did not revise the exemptions for ponds of clean produced water. The Staff 

Report also addresses why clean produced water is handled differently in SJVUAPCD 

than in South Coast Air Quality Management District (SCAQMD). Staff Report at 9. 

Generally, facilities in SCAQMD do not use the exemption in Rule 1176 section (i)(5)(J) 

limiting VOC concentration to 5 mg/l because they do not send the clean produced water 

to ponds; instead, they send it to Los Angeles and Orange County municipal sewer 

systems. Id. Another option for handling clean produced water is reinjection; however, 

the District states that operators in SJVUAPCD have not been able to get permits to 

install reinjection wells. Id. EPA has independently confirmed this information that oil 

production facilities in the SCAQMD can dispose their wastewater in sanitary sewage 

systems or existing injection wells.

2

 

2 Phone conversation dated April 26, 2012, between Nicole Law (EPA) and Victor Juan (SCAQMD). 
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The District also analyzed the cost effectiveness of injecting clean produced water and 

treating clean produced water (including an analysis suggested by EPA), and found that 

neither option would be cost effective. App. B at B-3 to B-10. 

e. Exemptions for small producers and very small producers are broader than those found 

in analogous rules in other Districts. 

District retained the exemptions for small producers and very small producers because it 

determined that removing these exemptions from the rule would cause small producers to 

either comply with the rule requirements or install tanks to replace the sumps, either of 

which the District found to be not cost effective. Staff Report at 14, 21. 

The District reviewed the basis for retaining each exemption. Id. at 12-17. The District 

also evaluated the costs associated with sumps complying with Rule 4402’s requirements 

for covers, including associated costs such as sump replacement, and gas vapor collection 

and destruction systems.3 App. B at B-11 to B-17. The Staff Report explains that the 

sumps in its jurisdiction are excavations in the ground with unfinished and unlined sides 

and that installation of covers and seals on existing unlined excavations is not feasible 

because the sides of the sumps would erode; therefore, facilities in the District would 

have to install new lined sumps to comply with cover requirements. Staff Report at 17-

18. In addition, Appendix B states that gas vapor collection and control is necessary 

because of the danger from dissolved gases trapped under the cover. App. B at B-13 to 

B-17. 

The District estimates that the installation of a flexible floating cover would be 

approximately $19,435 per ton of VOC controlled on a 1000 sq. foot second stage heavy 

oil sump and approximately $157,400 per ton of VOC controlled on a1000 sq. foot third 

stage heavy oil sump. App. B at B-12 to B-14; Table B-10. 

The District estimates that the installation of rigid floating covers would be 

approximately $23,067 per ton of VOC controlled on a 1000 sq. foot second stage heavy 

oil sump and approximately $190,264 per ton VOC controlled on a1000 sq. foot third 

stage heavy oil sump. App. B at B-14 to B-16; Table B-10. The Staff Report also states 

that the cost effectiveness for a 500 sq. foot third stage heavy oil sump equipped with a 

rigid floating roof would be $349,511. Staff Report at 19, Table 7. 

The District estimates that the installation of a sump cover equipped with an air pollution 

control device would be approximately $20,745 / ton of VOC controlled on a 1000 sq. 

 

3

The District’s analyses for cover requirements also included costs for excavating the sump to create level and 

vertical surfaces; lining of the sump with reinforced concrete; piping through the concrete walls; supports at the 

bottom of the sump to support the rigid floating cover at low fluid levels; additional costs of emptying existing 

sumps and temporary storage of their contents; installation and operation costs of a vapor compressor and an air 

pollution control device (flare) to control combustible gases such as methane collected under the cover for safety 

reasons. App. B at B-11 to B-17. 
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foot second stage heavy oil sump and approximately $167,202 / ton VOC controlled on a 

1000 sq. foot third stage heavy oil sump. App. B at B-16 – B-17; Table B-11. The Staff 

Report estimates the cost effectiveness for a 500 sq. foot third stage heavy oil sump 

equipped with a rigid fixed cover and an air pollution control device to be $115,426 per 

ton VOC reduced. Staff Report at 20, Table 8. 

The District also evaluated the cost effectiveness of installing a tank to replace a sump 

because its experience has been that facilities will install a tank rather than equip sumps 

with covers. Staff Report at 13; App. B at B-11. The District estimated that such costs 

would be $27,924 / ton VOC reduced to replace a second stage heavy oil sump and 

$255,057 / ton VOC reduced to replace a third stage heavy oil sump (assuming 90% 

control efficiency). App. B at B-20, Table B-12. On the basis of this analysis, the District 

concluded that replacing sumps with tanks would not be cost effective. Although we 

question the assumption in the District’s analysis that two tanks are needed to replace one 

sump,

4 

our calculation, based on the District numbers provided in App. B at B-19, 

indicates that the cost effectiveness based on one tank would be approximately $15,000 / 

ton VOC reduced,5which exceeds what is generally considered RACT. 

f. The gap and seal requirements for rigid floating covers are not as stringent as 

requirements in South Coast and San Luis Obispo rules. 

The District did not revise Rule 4402 to require more stringent controls for gaps and seals 

 

4 The District’s assumption that two tanks are needed to replace one existing sump results in a higher cost per ton of 

VOC controlled value compared to the cost of one tank replacing one sump. According to the District Appendix E, 

Addendum, redundant systems are necessary for both large and small producers. During a field visit to an affect 

facility on December 7, 2011, however, EPA staff observed that redundancy for a secondary separation tank (which 

had replaced a sump) was achieved by either of the two storage tanks at the facility. Thus, the sump was replaced 

by a single tank and existing storage capacity allowed for redundancy. 

5

 EPA calculation based on the calculation found in Appendix B of the Staff Report on B-19, 

Capital cost for one 5,000 bbl welded tank: $344,000 

Operating and labor cost for cleaning one tank: 

(1 hr/day x 365 days/year) + (72 hrs/tank x 1 tank/year) = 437 hrs/year 

437 hrs/year x $65/hr = $28,405/year 

Hazardous waste cost during cleaning (not including labor, $5/gallon x 3,000 gallons) for one tank: $15,000 in 1994 

dollars 

Annualized annual cost adjusted to 2011 dollars assuming 2.75% inflation/year($15,000/year)(1+0.0275(2011-

1994))=$22,012.5 per year 

Annualized costs: A = P x CRF where, A = Annualized total capital investment cost 

P = present value of capital 

CRF = capital recovery factor = i(i+1)n / (i+1)n-1 

i = interest rate = 10% 

n = useful lifetime of equipment in years = 10 

CRF = 0.1(0.1 +1)10 / (1+0.1)10 - 1 = 0.1627; so, 

A = ($344,000) x 0.1627 + $28,405 + $22,012.5 = $106,386.3/yr 

VOC Emissions from Heavy Oil Sumps were determined as follows: 

2nd stage: 1,000 ft2 x 0.0412 lb/ft2-day = 41.2 lb VOC/day = 7.52 tons VOC/year 

Assuming 90% control efficiency: $106,386.3 ÷ (0.90x7.52 tons)= $15,719 per ton of VOC controlled 
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on rigid floating covers.6 The Staff Report states that there are no sumps with covers in 

the District. Staff Report at 17. Based on our discussions with the District, it is EPA’s 

understanding that all sumps located in the San Joaquin Valley claim to be exempt from 

Rule 4402’s cover requirements in Section 5.0 on the basis of at least one of the 

exemptions in Section 4.0 of the rule. In addition, the District states that, historically, 

operators required to have covers have elected to instead install tanks. App. B at B-11. 

As noted in the Background section above, the District’s 2007 inventory shows that there 

are no first stage (primary) sumps in the Valley and only one sump at a large operation. 

In addition, according to the 2007 inventory, all but 16 sumps in the Valley are related to 

the production of heavy oil. Thus, it would appear that, in the Valley, all primary sumps, 

and nearly all sumps at large operations have been eliminated, and their operations most 

likely converted to tanks. 

We are concurring with the District’s conclusion that additional controls are not required 

to implement RACT at this time. We note the statement in the Staff Report that no sumps 

in the Valley are equipped with covers; thus, additional gap and seal requirements for 

rigid floating covers would not achieve additional emission reductions. In addition, as 

discussed above, the District has found that additional controls would not be costeffective. Staff Report at 17-19; App. B at B-14 to B-17. For these reasons, we concur 

with the District’s decision to not revise the rule to add additional seal and gap 

requirements for rigid floating covers. 

g. Fixed roof covers are not required to be equipped with an air pollution control device, in 

contrast to South Coast and Santa Barbara rules. 

The District did not revise Rule 4402 to require additional air pollution control (APC) 

devices for fixed roof covers. Similar to the discussion in the Staff Report relating to 

rigid floating covers, the Staff Report states, “no operators have ever installed a sump 

cover and distributers do not know of any facility in California that has a sump cover.” 

Staff Report at 19-20. Again, as we noted above in relation to rigid floating covers, it is 

EPA’s understanding that all sumps located in the San Joaquin Valley claim to be exempt 

from Rule 4402’s cover requirements in Section 5.0 on the basis of at least one of the 

exemptions in Section 4.0 of the rule. 

We are concurring with the District’s conclusion that additional controls are not required 

to implement RACT at this time. We note the statement in the Staff Report that no sumps 

in the Valley are equipped with covers. Id. at 21. Thus, a requirement for fixed covers to 

be equipped with an APC device would not achieve additional emission reductions. In 

addition, as discussed above, the District has found that additional controls would not be 

cost-effective. Staff Report at 19-20; App. B at B-16 to B-17. For these reasons, we 

concur with the District’s decision to not revise the rule to add air pollution control 

 

6

The Staff Report explains that there are no sumps in either South Coast or San Luis Obispo air districts. Staff 

Report at 17. We understand the District to mean that there are no unlined excavations in these Districts used for oil 

water separation in oil and gas production activities. 
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requirements for fixed roof covers. 

h. Periodic inspections of covers to ensure proper operation are not required in the rule. 

The District did not add a requirement for periodic inspections of covers because it 

determined that “no sumps in the Valley have covers or associated APC equipment.” 

Staff Report at 21. The District also stated that an inspection requirement and the 

removal of exemptions would drive facilities to replace sumps with tanks, which is not a 

cost effective option. 

For the above reasons, EPA has determined that SJVUAPCD’s Rule 4402 as adopted on 

December 15, 2011 has adequately addressed the deficiencies identified in EPA’s July 7, 2011 

simultaneous limited approval and limited disapproval. 

VII. Recommendations for Future Revisions

The following revisions are not currently the basis for rule disapproval, but are recommended as 

improvements when this rule is amended. 

a. We recommend SJVUAPCD develop a more current inventory of all oil production 

sumps, ponds, and pits in the District for its next ozone plan. This inventory could 

identify the number of sumps and ponds by size, type (lined, unlined, excavation, above 

ground, etc.), VOC content and operator production rate. A new inventory might 

support adjustments to exemptions, such as the cut-offs for sumps with specific surface 

areas, as appropriate. 

b. In the near future, we recommend the District consider whether technology and cost 

effectiveness estimates for this source category have changed to support the following 

rule revisions: 

1. Require rigid floating covers to have seals and restrict the gap allowed for such 

covers to 1/8” for a cumulative length of 95% of the perimeter, with no single gap 

in excess of 1⁄2 inch; 

2. Require that fixed covers be equipped with a 95% efficient APC device; 

3. Require periodic inspection of covers and APC equipment to ensure proper 

operation. 

VIII. EPA Action

The February 2012 submittal of Rule 4402 adequately addresses all deficiencies identified in our 

July 2011 final action, and fulfills the relevant CAA requirements. Consequently, EPA proposes 

a full approval of the December 15, 2011 adopted version of Rule 4402 and inclusion into the 

California SIP. If finalized, this action would terminate all FIP and sanction implications of our 

July 2011 limited disapproval. 
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IX. References

San Joaquin Valley Unified Air Pollution Control District Rule 4402- Crude Oil Production 

Sumps, as approved into the SIP on July 7, 2011. 

San Joaquin Valley Unified Air Pollution Control District Rule 4402- Crude Oil Production 

Sumps, as submitted on February 23, 2012. 

“Reasonably Available Control Technology (RACT) Demonstration for Ozone State 

Implementation Plans (SIP)” SJVAPCD, April 16, 2009. 

“Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) 

EPA OAQPS, May 25, 1988. 

“Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little 

Bluebook), EPA Region 9, August 21, 2001. 

“Final Staff Report for Revised Proposed Amendments to Rule 4402 (Crude Oil Production 

Sumps),” San Joaquin Valley Unified Air Pollution Control District, December 15, 2011. 

“Technical Support Document for Suggested Control Measure for the Control of Organic 

Compound Emissions from Sumps Used in Oil Production Operations,” California Air 

Resources Board, August 11, 1988. 

“2007 Area Source Emissions Inventory Methodology 310- Oil Production Fugitive Losses,” San 

Joaquin Valley Unified Air Pollution Control District, January 23, 2009. 

“Revisions to the California State Implementation Plan, San Joaquin Valley Unified Air 

Pollution Control District (SJVUAPCD),” 76 FR 39777, July 7, 2011. 

“Technical Support Document for EPA’s Notice of Proposed Rulemaking for the California State 

Implementation Plan as submitted by the California Air Resources Board: EPA’s Analysis of San 

Joaquin Valley Unified Air Pollution Control District’s Rule 4402, Crude Oil Production 

Sumps,” USEPA, October 2010. 

South Coast Air Quality Management District Rule 1176- VOC Emissions from Wastewater 

Systems, as amended on September 13, 1996. 

San Luis Obispo County Air Pollution Control District Rule 419- Petroleum Pits, Ponds, Sumps, 

Well Cellars, and Wastewater Separators, as adopted on June 12, 1994. 

Santa Barbara County Air Pollution Control District Rule 344- Petroleum Sumps, Pits, and Well 

Cellars, as adopted on November 10, 1994. 

District 4 Oil Production Facilities, as compiled by Nicole Law on January 24, 2012. 
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Email Correspondence and Attachments from Burton Ellison, DOGGR, to Stanley Tong, EPA 

on October 31, 2011. 

Phone conversation dated April 26, 2012, between Nicole Law (EPA) and Victor Juan 

(SCAQMD). 

California Air Resources Board 2007 Oil and Gas Industry Survey Results Final Report, 

December 2011.