SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX B: Rule Consistency Analysis June 16, 201 1

Final Draft Staff Report with Appendices

For Proposed Amendments to Ru le 4401 B - 1 

## APPENDIX B

Rule Consistency Analysis

June 16, 2011SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

APPENDIX B: Rule Consistency Analysis June 16, 201 1

Final Draft Staff Report with Appendices

For Proposed Amendments to Ru le 4401 B - 2 This page intentionally blank.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

APPENDIX B: Rule Consistency Analysis June 16, 201 1

Final Draft Staff Report with Appendices

For Proposed Amendments to Ru le 4401 B - 3 I. REQUIREMENTS OF ANALYSIS

Pursuant to Section 40727.2 of the California Healt h and Safety Code, prior to adopting,

amending, or repealing a rule or regulation, the Di strict is required to perform a written

analysis that identifies and compares the air pollu tion control elements of Proposed

Rule 4401 with the corresponding elements of existi ng or proposed District and United

States Environmental Protection Agency (EPA) rules, regulations, and guidelines that

apply to the same source category. The rule elemen ts that were analyzed are emission

limits or control efficiency, operating parameters and work practices, monitoring and

testing, and recordkeeping and reporting requiremen ts.

II. RESULTS OF ANALYSIS

A. District Rules

Rule 2520 (Federally Mandated Operating Permits) ap plies to oil production facilities,

gas production facilities, gas processing plants, p etroleum refineries, chemical plants,

and gas liquids processing plants if they major sou rces. The recordkeeping and

reporting requirements of Proposed Rule 4401 are no more stringent than the

provisions of Rule 2520. Proposed Rule 4401 requir es inspection records to be

submitted upon request of the APCO while Rule 2520 requires the submission of

records every six months.

B. United States Environmental Protection Agency Ru les and Regulations

District staff found no Control Technique Guideline s (CTG) or any standards in 40 CFR

60, Title 40 (Protection of Environment), Chapter I , Subchapter C (Air Programs, Part 60

(Standards of Performance for New Stationary Source s) and Part 63 (National Emission

Standards for Hazardous Air Pollutants for Source C ategories) applicable to equipment

leaks from steam-enhanced crude oil production well vents.

EPA recordkeeping policy requires records be kept f or a period of at least five years.

The recordkeeping period specified in Proposed Rule 4401 is five years. EPA policy

basically stated that any provision in the rule tha t allows for an automatic exemption for

excess emissions due to malfunction, start-up, or s hutdown is prohibited. Proposed

Rule 4401 does not contain an exemption during star t-up or shutdown. However, the

rule contains provisions that allow operators to re pair or replace leaking components as

expeditiously as practicable but not later than the timeframes specified in the rule.

District staff believes that the limited repair of leaking components including the leak

minimization requirements of Proposed Rule 4401 are consistent with EPA policy.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

APPENDIX B: Rule Consistency Analysis June 16, 201 1

Final Draft Staff Report with Appendices

For Proposed Amendments to Ru le 4401 B - 4 This page intentionally blank.