# PROPOSED June 16, 2011

   Proposed Rule 4401 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 [ Rule Adoption Date]

)

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 vapor collection and control systems.

3.0 Definitions

3.1 Air Pollution Control Officer ( APCO) : as defined 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”.

# PROPOSED June 16, 2011

   Proposed Rule 4401 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, any crude 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).

# PROPOSED June 16, 2011

   Proposed Rule 4401 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 6.2.5

.

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:

3.20.1 Effective until December 31, 2008, a reading as met hane on a portable hydrocarbon detection instrument (calibrated with m ethane) in excess of 10,000 ppm when measured in accordance with the tes t method specified

in Section 6.3.3.

# PROPOSED June 16, 2011

   Proposed Rule 4401 3.20.2 Effective on and after January 1, 2009, the

The dripping of VOC-containing liquid or the detection of a concentration of total organic compound, above background, determined acco rding 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 .2.1 and Section 3.20.2.2 of this rule. Any liquid or gas coming from a component undergoing re pair or replacement, or during sampling of process fluid from a component i nto a container is not considered a leak provided such activities are done as expeditiously as possible and with minimal spillage of material and VOC emiss ions 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

3.20.2 .1 Major Liquid Leak: a visible mist or a continuo us flow of liquid that is not seal lubricant.

3.20.2.2 Minor Liquid Leak: a liquid leak, except seal lub ricant, that is not a major liquid leak and drips liquid at a rate of more 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: any pump five (5) brake horsepower or larger, any compressor, or any pressure relief valve four (4) i nches in diameter 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.

# PROPOSED June 16, 2011

   Proposed Rule 4401 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).

3.29 Process Drain: any open portion of a non-continuous piping system, in cluding 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.

# PROPOSED June 16, 2011

  Proposed Rule 4401 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.

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: any 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: any steam drive well, cyclic well, or any other well in which the temperature of crude oil is raised, by the injection of steam, above the production zone temperature tha t existed 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.

# PROPOSED June 16, 2011

  Proposed Rule 4401 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.

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.

# PROPOSED June 16, 2011

  Proposed Rule 4401 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 Effective until December 31, 2008, the requirements of thi s rule for cyclic wells shall not apply to the first 100 cyclic wells of a small producer.

4.2 3 The requirements of this rule for cyclic wells sha ll not apply to up to 40 wells owned by a company and undergoing pilot testing pro vided;

4.2.1 4.3.1 the production zone on that property has not been injected with steam during the preceding two (2) years,

4.2.2 4.3.2 the well is located more than 1000 feet from an ex isting well vent vapor collection and control system operated by the company, and

4.2.3 4.3 .3 the operation is under District permit.

4.3 4 The requirements of this rule shall not apply to up to 40 cyclic wells owned by a company and undergoing well stimulation, provided;

4.3.1 4.4.1 the well is located more than 1000 feet from an ex isting well vent vapor collection and control system operated by the company, and

4.3.2 4.4.2 the operation is under District permit.

4.4 5 Effective until December 31, 2008, the requirement s of this rule shall not apply to up to 20 cyclic wells owned by a compan y in each stationary source as defined in Rule 2201 (New and Modified Stationary Source Revie w Rule), provided the requirements of Section 4.5.1 and Section 4.5.2 are met. Effective on and after January 1, 2009, the 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 St ationary Source Review Rule), and up to 20 cyclic wells owned by a small p roducer, provided the requirements of Section 4.4.1 and Section 4.4.2 4.5.1 and Section 4.5.2 are met.

4.4.1 4.5.1 the well is located more than 1000 feet from an ex isting well vent vapor control system operated by the company, and

4.4.2 4.5.2 the operation is under District permit.

# PROPOSED June 16, 2011

  Proposed Rule 4401 4.6 Effective until December 31, 2008, the requirements of this rule shall not apply to the first ten (10) wells of a small producer tha t are responding to steam injected from an operator other than themselves and where no contractual agreement fo r injected steam exists, and provided the small producer meets the f ollowing

conditions:

4.6.1 A list of wells that are exempted by Section 4.6 sh all be submitted to the APCO by July 15, 1998.

4.6.2 Source testing of the well vent that is nearest to the steam injection well shall be conducted by January 15, 2001 in order to determine its VOC mass emission rate. Source testing shall be conduc ted in accordance with

Section 6.3.4.

4.5 4.7 The requirements of this rule shall not apply to c omponents serving the produced fluid line.

4.6 4.8 Except for complying with the applicable requireme nts 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. 4.8.1 thr ough

Section 4.8.4. An operator claiming an exemption pursuant to Sec tion 4.6 4.8 shall provide proof of the applicable criteria to t he satisfaction of the APCO.

4.6.1 4.8.1 Pressure relief devices, pumps, and compressors th at are enclosed and whose emissions are controlled with an operatin g VOC collection and control system as defined in Section 3.0.

4.6.2 4.8.2 Components buried below ground.

4.6.3 4.8.3 Components used exclusively in vacuum service.

4.6.4 4.8.4 One-half inch nominal or less stainless steel tube fittings which

have been demonstrated to the APCO to be leak-free based on initial inspection using the test method specified in Secti on 6.3.3.

4.7 9 E ffective on and after January 1, 2009, the The requirements of Section 5.4.1 through Section 5.4.7 5.8.1 through Section 5.8.5 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. 6.3.5.

# PROPOSED June 16, 2011

  Proposed Rule 4401 5.0 Requirements

Section 5.1 through Section 5.4 shall be effective until December 31, 2008. Section 5.5 through Section 5.9 shall be effective on and after January 1, 2009.

5.1 No person shall operate a steam

- enhanced crude oil production well, except cyclic

we lls meeting the requirements of Section 5.4, unless the uncontrolled VOC emissions from any well vent are reduced by at leas t 99 percent by weight, or

5.2 If several steam

- enhanced crude oil production well vents are connec ted to a vapor

collection and co ntrol system, the total uncontrolled VOC emissions shall be reduced by at least 99 percent by weight.

5.3 All components of a well vent vapor collection and control system shall be maintained in good repair. A total number of leaks is a violation of this rule if it exceeds the number of allowable leaks. Vapor colle ction and control systems serving 501 or more wells shall be determined to be in violation of the number of allowable leaks if more than one (1) leak is detect ed for each 20 wells tested with

a minimum of 50 wells tested.

Table 2 Number of Allowable Leaks

Number of Steam

- Enhanced Crude Oil Production Wells Connected to a Vapor Collection and Control System Number of

Allowable Leaks

Up to and including 25 3

26 to 50 6

51 to 100 8

101 to 25 0 10

251 to 500 15

5.3.1 An operator, upon detection of a leak, shall affix a readily visible tag bearing the date on which the leak is detected. Th e tag shall remain in place until the leaking component is repaired. Fai lure to repair a leak

within fi fteen (15) calendar days shall constitute a violati on of this rule. The APCO may grant a ten (10) calendar day extensio n provided the operator demonstrates that necessary and sufficient actions have and are being taken to correct the leak. Failure to rep air a leak after a ten (10) calendar day extension constitutes a violation of t his rule.

5.3.2 For the purpose of Section 5.3, components of the w ell vent vapor collection and control system shall include all pip ing, valves, fittings,

pumps, compressors, tanks, etc. used to collect, control, store, or dis pose of VOC condensate or non

- condensable VOCs prior to blending of VOC

# PROPOSED June 16, 2011

   Proposed Rule 4401 condensate with crude oil or blending of non

- condensable VOCs with gases to be used as a fuel.

5.4 No person shall operate a cyclic well located on properties with less than ten (10) cyclic wells, owned by a company, unless the uncont rolled VOC emissions from any well vent or system of well vents connected to a single vapor collection and control device are reduced by at least 50 perce nt. Properties shall include contiguous and adjacent oil production properties o wned by or under control of the company.

5.1 5 An operator shall not operate a steam-enhanced cru de oil production well unless the operator complies with the requirements of eith er Section 5.1.1 or Section

5.1.2. 5.5.1 or Section 5.5.2.

5.1.1 5.5.1 The steam-enhanced crude oil production well vent is closed and the front line production equipment downstream of t he wells 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 5.5.2 The steam-enhanced crude oil production well vent is open and the

well vent is connected to a VOC collection and cont rol system as defined

in Section 3.0.

5.2 6 Determination of Compliance with the Leak Standards

5.2.1 5.6.1 An operator shall be in violation of this rule if any District inspection demonstrates that one or more of the con ditions in Section 5.2.2

5.6.2 exist at the facility or if any operator inspectio n conducted pursuant

to Section 5.4 5.8 demonstrates that one or more of the conditions in

Section 5.2.2 5.6.2 exist at the facility.

5.2.2 5.6.2 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. 5.6.1:

5.2.2.1 5.6.2.1 Existence of an open-ended line or a valve located

at the end of the line that is not sealed with a bl ind flange, plug, cap, or a second closed valve that is not closed at all times, except during attended operations requiring process fluid flow

# PROPOSED June 16, 2011

   Proposed Rule 4401 through the open-ended lines. Attended operations include draining or degassing operations, connection of tem porary process equipment, sampling of process streams, eme rgency venting, and other normal operational needs, provid ed such operations are done as expeditiously as possible an d with minimal spillage of material and VOC emissions to t he atmosphere.

5.2.2.2 5.6.2.2 Existence of a component with a major liquid leak

as defined in Section 3.0.

5.2.2.3 5.6.2.3 Existence of a component with a gas leak greater than 50,000 ppmv.

5.2.2.4 5.6.2.4 Existence of a component leak described in Section 5.2.2.4.1 through Section 5.2.2.4.3 5.6.2.4.1 through Section

5.6.2.4.3 in excess of the allowable number of leaks specifi ed in

Table 2. 3.

5.2.2.4.1 5.6.2.4.1 A minor liquid leak, or

5.2.2.4.2 5.6.2.4.2 A minor gas leak, or

5.2.2.4.3 5.6.2.4.3 A gas leak greater than 10,000 ppmv up to

50,000 ppmv.

Table 2 3 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.

# PROPOSED June 16, 2011

   Proposed Rule 4401 5.3 7 An operator shall comply with the following operat ing requirements:

5.3.1 5.7.1 An operator shall not use any component with a lea k as defined in Section 3.0, or that is found to be in violation of the provisions of Section

5.2.2 5.6.2 . However, components that were found leaking may be used provided such leaking components have been identifi ed with a tag for repair, are repaired, or awaiting re-inspection aft er being repaired within the applicable time frame specified in Section 5.5 5.9 of this rule.

5.3.2 5.7.2 Each hatch shall be closed at all times except dur ing sampling or adding of process material through the hatch, or du ring attended 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 5.7.3 An operator shall comply with the requirements of Section 6.7 if there is any change in the description of major com ponents or critical

components.

5.4 5.8 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 5.8.1 Except for pipes and unsafe-to-monitor components, an operator shall inspect all other components pursuant to the requirements of Section 6.3.3 at least once every year.

5.4.2 5.8.2 An operator shall visually inspect all pipes at le ast once every year. Any visual inspection of pipes that indicates a le ak that cannot be immediately repaired to meet the leak standards of this rule shall be inspected within 24 hours after detecting the leak. If a leak is found, the leak shall be repaired as soon as practicable but n ot later than the time frame specified in Table 3 4 of this rule.

5.4.3 5.8.3 In addition to the inspections required by Section 5.4.1 5.8.1 , an operator shall inspect for leaks all accessible ope rating pumps, compressors, and PRDs in service as follows:

5.4.3.1 5.8.3.1 An operator shall audio-visually (by hearing and by sight) inspect for leaks all accessible operatin g pumps, compressors, and PRDs in service at least once each calendar

week.

# PROPOSED June 16, 2011

   Proposed Rule 4401 5.4.3.2 5.8.3.2 Any audio-visual inspection of an accessible operating pump, compressor, and PRD performed by an operator that indicates a leak that cannot be immed iately repaired to meet the leak standards of this rule sh all be inspected not later than 24 hours after conducting the audiovisual inspection. If a leak is found, the leak sh all be repaired as soon as practicable but not later than the time frame specified

in Table 3 4 of this rule.

5.4.4 5.8.4 In addition to the inspections required by Section 5.4.1 5.8.1

, Section 5.4.2 5.8.2 and Section 5.4.3 5.8.3 , an operator shall perform the following inspections:

5.4.4.1 5.8.4.1 An operator shall initially inspect a PRD that releases to the atmosphere as soon as practicable b ut not later than 24 hours after the discovery of the release. An op erator shall reinspect the PRD not earlier than 24 hours after the initial inspection but not later than 15 calendar days after the initi al inspection.

5.4.4.2 5.8.4.2 An operator shall inspect all new, replaced, or repaired fittings, flanges, and threaded connection s within 72 hours of placing the component in service.

5.4.4.3 5.8.4.3 Except for PRDs subject to the requirements of Section 5.4.4.1, 5.8.4.1, an operator shall inspect a component that has been repaired or replaced not later than 1 5 calendar days after the component was repaired or replaced.

5.4.7 5.8.5 An operator shall inspect all unsafe-to-monitor co mponents during

each turnaround.

5.4.8 5.8.6 A District inspection in no way fulfills any of th e mandatory inspection requirements that are placed upon operat ors and cannot be used or counted as an inspection required of an operator

.

5.5 5.9 Leak Repair Requirements

5.5.1 5.9.1 An operator shall affix a readily visible weatherp roof tag to a leaking component upon detection of the leak. An o perator shall include the following information on the tag:

5.5.1.1 5.9.1.1 The date and time of leak detection.

5.5.1.2 5.9.1.2 The date and time of leak measurement.

# PROPOSED June 16, 2011

   Proposed Rule 4401 5.5.1.3 5.9.1.3 For a gaseous leak, the leak concentration in

ppmv.

5.5.1.4 5.9.1.4 For a liquid leak, whether it is a major liquid le ak or a minor liquid leak.

5.5.1.5 5.9.1.5 Whether the component is an essential component, an unsafe-to-monitor component, or a critical compo nent.

5.5.2 5.9.2 An operator shall keep the tag affixed to the comp onent until an operator has met all of the following conditions:

5.5.2.1 5.9.2.1 Repaired or replaced the leaking component, and

5.5.2.2 5.9.2.2 Re-inspected the component using the test method in Section 6.3.3, and

5.5.2.3 5.9.2.3 The component is found to be in compliance with the requirements of this rule.

5.5.3 5.9.3 An operator shall minimize a component leak in ord er 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 5.9.4 Except for leaking critical components or leaking essential components subject to the requirements of Section 5 .5.7 5.9.7 , if an operator has minimized a leak but the leak still ex ceeds the applicable leak 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 5.9.4.1, Section 5.9.4.2, or Section 5.9.4.3 as soon as practicable but not later than the time period specified in Table 3. 4.

5.5.4.1 5.9 .4 .1 Repair or replace the leaking component; or

5.5.4.2 5.9.4.2 Vent the leaking component to a VOC collection and control system as defined in Section 3.0, or

5.5.4.3 5.9 .4 .3 Remove the leaking component from operation.

# PROPOSED June 16, 2011

   Proposed Rule 4401      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 5.9.5 The leak rate measured after leak minimization has been performed shall be the leak rate used to determine the applic able repair period specified in Table 3. 4.

5.5.6 5.9.6 The time of the initial leak detection shall be th e start of the repair period specified in Table 3. 4.

5.5.7 5.9.7 If the leaking component is an essential component 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 Effective January 15, 1998, a A small producer shall maintain monthly records of county-specific crude oil production. F or the purpose of this rule, the monthly crude oil production records requ ired by the California

# PROPOSED June 16, 2011

   Proposed Rule 4401 Division 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 Effective until December 31, 2008, the resu lts of source tests conducted pursuant to Section 4.6.2 shall be submitted to the APCO within 60 days after the completion of the source test.

6.1.4 6.1.5 Effective on and after January 1, 2009, t he The inspection log maintained pursuant to Section 6.4.

6.1.5 6.1.6 Effective on and after January 1, 2009, r R ecords of each calibration of the portable hydrocarbon detection i nstrument utilized for inspecting components, including a copy of current calibration gas certification from the vendor of said calibration g as cylinder, the date of calibration, concentration of calibration gas, inst rument reading of calibration gas before adjustment, instrument readi ng of calibration gas after adjustment, calibration gas expiration date, and calibration gas cylinder pressure at the time of calibration.

6.1.6 6.1.7 Effective on and after January 1, 2009, an An operator shall maintain copies at the facility of the training rec ords of the training program operated pursuant to Section 6.5.

6.1.7 6.1.8 Effective on and af ter January 1, 2009, a n An operator shall keep a copy of the APCO-approved Operator Management Pla n at the facility.

6.1.8 6.1.9 An operator shall keep submit to the APCO not later than June 14, 2007 a list of all gauge tanks, as defined in Section 3 .0 3.17 . The list shall contain the size, identification number, the location of each gauge tank and specify whether the gauge tank is up stream of all front line production equipment.

6.1.9 6.1.10 The results of gauge tank TVP testing conducted pu rsuant to
Section 6.2.3 6.2.5 shall be submitted to the APCO within 60 days after the completion of the testing.

6.1.10 6.1.11 Effective on and after January 1, 2007, an An operator that

discovers that a PRD has released shall record the date that the release was discovered, and the identity and location of th e PRD that released.

# PROPOSED June 16, 2011

   Proposed Rule 4401 An operator shall submit such information recorded during the calendar year of the release to the APCO no later than 60 da ys after the end of the calendar year.

6.2 Compliance Source Testing

6.2.1 An operator shall source test annually all VO C vapor 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 EPA, ARB, and the APCO, an operator need not comply with the annual testing requirement of a VOC collection and control system is not subject to Section 6.2.1 if all uncondensed VOC emissions collected by a vapor collection and control the system are controlled by a device meeting one of the requirements in Sections 6.2.2.1 through

6.2.2.3. incinerated in fuel burning equipment, an interna l combustion engine or in a smokeless flare.

6.2.2.1 An internal combustion engine subject to District Rule 4702

(Internal Combustion Engines – Phase 2); or

6.2.2.2 A combustion device subject to District Rule 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 MMBtu/hr to 5 MMBtu/hr); or District Rule 4308 (Boi lers, 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 (Flares).

6.2.3 If approved by EPA, ARB, and the APCO, an operator need not comply with the annual testing requirement of Section 6.2. 1 for a vapor control system which does not have a VOC destruction d evice.

6.2.4 An operator seeking approval pursuant to Section 6. 2.2 or Section 6.2.3 shall submit a written request and supporting infor mation to the APCO. The District shall evaluate the request and if appr oved by the APCO, the District shall provide EP A and ARB with a copy of the evaluation and

# PROPOSED June 16, 2011

   Proposed Rule 4401 shall request EPA and ARB approval. The District e valuation and the APCO request shall be deemed approved unless EPA or ARB objects to such approval in writing within 45 days of the rece ipt of the APCO

request.

6.2.3 6.2.5 An operator shall comply with the following requir ements for each gauge tank, as defined in Section 3.0: 3.17 :

6.2.3.1 6.2.5.1 Conduct an initial TVP testing of the produced fluid in each gauge tank not later than June 14, 2007

. Thereafter , an

An operator shall conduct periodic TVP testing of each gauge tank at least once every 24 months du ring summer (July – September), and whenever there is a change in the source or type of produced fluid in the gauge t ank.

6.2.3.2 6.2.5.2 The TVP testing shall be conducted at the actual storage temperature of the produced fluid in the ga uge tank using the applicable TVP test method specified in S ection 6.4 of Rule 4623 (Storage of Organic Liquids). The operat or shall submit the TVP testing results to the APCO as speci fied in

Section 6.1.9. 6.1.10.

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 Section 6.3.5 may be used provided that such equivalent test methods have been previously approved, in writ ing, by the EPA, 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.

# PROPOSED June 16, 2011

  Proposed Rule 4401 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 instrument probe inlet at a distance of one (1) centimeter or less from the surface of the component interface.

6.3.4 Effective until December 31, 2008, for the purpose of Section 4.6.2, the

VOC mass emission rate shall be determined acc ording to the procedures

described in the document USEPA

- 909/9

- 81

- 003, September 1981,

entitled “Assessment of VOC Emissions from Well Ven ts Associated with Thermally Enhanced Oil Recovery”.

6.3.4 6.3.5 The VOC content by weight percent (wt.%) shall be determined using American Society of Testing and Materials (AS TM) D1945 for gases and South Coast Air Quality Management District (SC AQMD) Method 304-91 or the latest revision of ASTM Method E168, E169 or E260 for liquids.

6.4 Inspection Log

Effective on

and after January 1, 2009, an An operator shall maintain an inspection log in which an operator records, at a m inimum, 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.

# PROPOSED June 16, 2011

   Proposed Rule 4401 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.

6.5 Employee Training Program

Effective on and after January 1, 2009, an An operator shall establish and implement an employee training program for inspecti ng and repairing components and recordkeeping 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.

# PROPOSED June 16, 2011

   Proposed Rule 4401 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 4.8 (except for components buried below ground) may be describe d 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 Sections 4.6 4.8 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 of 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 after 2008 , an operator shall submit to the APCO for approval, in writing, an annual report indicating a ny 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.

# PROPOSED June 16, 2011

   Proposed Rule 4401 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, which commences steam

- enhancement operations on or after April 11, 1991, shall comply with the requirements of this rule an d 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 c omponents that are exempt pursuant to Section 4.2, 4.3, 4.4, 4.6, or 4.7 4.3, 4.4, 4.5, 4.8 or 4.9 that become subject to this rule through loss of exempti on status shall not be operated until such time that they are in full comp liance with the requirements

of this rule.

7.3 Effective o n and after January 1, 2009, an operator shall be i n full compliance with the requiremen

ts of this rule, unless otherwise specified in the provisions of

this rule.

# PROPOSED June 16, 2011

   Proposed Rule 4401 This page intentionally blank.