SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Addendum December 15, 2011 

E - 1 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

APPENDIX E 

Addendum 

December 15, 2011 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Addendum December 15, 2011 

E - 2 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Addendum December 15, 2011 

E - 3 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

Replacement Tanks 

District staff performed a cost effectiveness analysis of replacing a sump with a tank 

system to determine whether or not is it a cost effective option. Historically, when an 

operator has been required to cover a sump they respond by replacing the sump with a 

tank system. Conversations with affected sources, industry representatives, and 

vendors have confirmed that operators will continue to respond in this manner in the 

future. The Air Resources Board (ARB) further supports this in the technical support 

document (TSD) by stating “We believe that a fixed-roof tank operated at a constant 

liquid level is the logical choice for sump replacement.”(TSD1

, p51) 

Under two scenarios, District staff performed cost effectiveness analyses for replacing a 

sump with 1) a closed roof tank system with a PV vent and 2) a closed roof tank system 

with vapor controls. District staff determined costs for the analyses using a combination 

of data from the District permit database, information provided in the ARB TSD, and 

information provided by affected sources, manufacturers, and vendors. 

The production of crude oil is a complex, continuous process that involves numerous 

equipment located in various locations throughout a plot which requires the use and 

availability of sumps, or tanks, at all times to handle or process the incoming oil and 

water. To ensure continuous operations, facilities have installed redundant systems 

that handle situations of unforseen breakdowns and/or periodic cleaning and 

maintenance. If an operator is forced to halt production, the consequences may cost 

millions of dollars in analysis, drilling of new wells, and moving and/or rebuilding of 

infrastructure if they are unable to resume oil production. 

Representatives from the Environmental Protection Agency (EPA), ARB, and the 

District toured two oil production facilities in the Valley together; by District standards, 

one facility is considered a small producer and the other facility is a large producer. 

Operators at both facilities confirmed this necessity of redundant systems at their 

facilities and the consequences of not having it. The facilities toured implemented 

redundant systems unique to each operation. For the large producer, each process 

point (i.e. storage tanks, reject tanks, surge tanks, LACT tanks, Wemcos, etc.) all had 

duplicative tanks that allowed the facility to continue operation while cleaning/repairing a 

unit. Similarly, the small producer also implemented redundant systems in their 

processes and ensuring continuous operation by utilizing their equipment to serve 

multiple purposes. 

To analyze the cost of replacing a sump with a tank system, District staff determined 

that each sump would be required to be replaced with at least two tanks of equivalent 

capacity to account for the required redundancy necessary for clean-up and 

maintenance of each tank. Clean-up and maintenance of tanks is a new operating 

 

1

 ARB TSD for the Suggested Control Measure of the Control of Organic Compound Emissions from 

Sumps Used in Oil Production Operations
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Addendum December 15, 2011 

E - 4 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

procedure that operators would incur after replacing a sump with a tank system, 

because operators do not need to clean and maintain the sumps on a frequent or 

regular basis. 

Based on the discussion above, the installation of two tanks is a valid and necessary 

cost for the replacement of an existing sump. For a detailed discussion of the cost 

effectiveness of replacing sumps with tanks please refer to the Appendix B of the final 

draft staff report for revised proposed amendments to District Rule 4402.