Santa Barbara County APCD Rule 344 344 - 1 November 10, 1994

RULE 344. PETROLEUM SUMPS, PITS AND WELL CELLARS. (Adopted 11/10/1994)

A. Applicability

This rule applies to sumps, pits and well cellars at facilities where petroleum is produced, gathered,

separated, processed or stored.

B. Exemptions

1. The provisions of this rule shall not apply to spill containments.

2. The provisions of this rule shall not apply post tertiary sumps and post tertiary pits.

3. Sections D, E, F and G.1 of this Rule shall not apply to:

a. Post-primary sumps or pits meeting any of the following criteria:

1) monthly ROC loss across the sump of less than 75 pounds.

2) producer oil shipment from all operations within Santa Barbara County of

less than 150 barrels of oil per day averaged over the year preceding the year

for which the exemption is claimed, or

3) shut in sumps or pits that are empty with all inlets plugged, capped, or blind

flanged.

b. Pits used less than 30 days per year. Pits are in use when either receiving or storing

petroleum product.

4. Post primary sumps or pits with surface area less than 1000 square feet.

5. Sections F and G.1 of this Rule shall not apply to components which are subject to Rule 331

as components is defined in Rule 331.

6. Sections D.3 and D.4 of this rule shall not apply to wells that have been idle for more than six

months immediately prior to inspection as indicated by production records.

C. Definitions

See Rule 102 for definitions not restricted to interpretation of this Rule.

"Capture efficiency" means the weight per unit time of ROC entering a capture system and delivered

to a control device divided by the weith per unit time of total ROC generated by the source of ROC

expressed as a percentage.

"Control" means the reduction, by destruction or removal, of the amount of ROCs in a gas stream

prior to discharge to the atmosphere.

"Control efficiency" means the percentage of ROCs entering control equipment that is not present in

the exhaust of that control equipment to the atmosphere.

"Defect" means a condition, including but not limited to a tear, hole or lack of required

vapor-tightness, that creates a substantial chance of reducing the effectiveness of the control device.
Santa Barbara County APCD Rule 344 344 - 2 November 10, 1994

"Facility" means a structure, building, oil lease, or operation, that has one or more permitted pieces of

equipment.

"Fixed Roof Cover" means any cover that is not in contact with a liquid surface, but is placed over and

completely encloses the liquid surface.

"Floating Cover" means any cover that floats on a liquid surface and prevents evaporation of the

liquid under the cover into the atmosphere.

"Overall efficiency" means the emission reduction, expressed as a percentage, that results from the

combined effect of capture and control of ROCs that would be emitted to the atmosphere from a

container in the same product service without capture and control of emissions.

"Pit" means a basin the purpose of which is collection of emergency or intermittent streams of liquid

under normal operations.

"Primary Sump" means any sump that receives a stream of crude oil and produced water directly from

one or more oil production wells or field gathering systems.

"Post-primary Sump" means a sump that receives a stream from one or more previous separation

processes.

"Post-Tertiary Sump" means a sump that receives a liquid stream that has undergone three or more

previous separation processes.

"Sump" means a lined or unlined surface impoundment or depression in the ground that, during

normal operations, is used for separating oil, water, and solids in oil production operations.

"Vapor tight" means that a seal or closure prevents the emission of volatile organic compounds which

would cause an appropriate analyzer to register more than 10,000 parts per million by volume

expressed as methane.

"Well cellar" means a lined or unlined containment into which one or more wellheads are installed.

For the purposes of this rule, well cellars are not sumps or pits.

D. Requirements - Emission Reduction

1. Primary sumps shall not be installed or used.

2. Pits and post-primary sumps shall be

a. replaced by a tank that complies with Rule 325, or

b. provided with any of the following:

1) a flexible floating cover or a rigid floating cover equipped with seals.

2) a fixed roof cover equipped with a pressure vacuum relief valve and a closed

vent system that collects and delivers vapors to a vapor recovery system, gas

gathering system or an air pollution control device with a control efficiency

of 95 percent by weight or greater.
Santa Barbara County APCD Rule 344 344 - 3 November 10, 1994

3) other equipment having overall efficiency of at least 80 percent by weight.

Costs incurred by the APCD for the review, testing and approval of an

alternate control device may be recovered pursuant to the cost reimbursement

provisions of Rule 210.

3. Well cellars

a. A person shall not open any valve at the wellhead without using a portable container

to catch and contain any organic liquid that would otherwise drop on the ground or

into the well cellar. Such container shall be kept closed when not in use.

b. Immediately before a well is steamed or after a well head is steam cleaned, the well

cellar in which it is located shall be pumped out.

c. Neither of the following conditions shall occur unless the owner or operator

discovered the condition and the well cellar is pumped within 7 days of discovery:

1) liquid depth exceeding 50 percent of the depth of the well cellar.

2) oil/petroleum depth exceeding 2 inches.

If a well cellar cannot be accessed by a vacuum truck due to muddy conditions, the

well cellar shall be pumped as soon as it becomes accessible.

4. Well heads not in well cellars are subject to Section D.3.a.

E. Requirements - Covers

1. The cover material shall be impermeable to ROCs. Metal cover materials are impermeable for

the purposes of this requirement.

2. The cover material shall be free from holes, tears, and openings.

3. Gauging and sampling devices on the cover shall be kept closed and vapor-tight except when

such devices are being used, inspected or repaired. Use, inspection and repair, within the

meaning of this requirement, must be attended by the person engaged in the use, inspection or

repair.

4. Cover drains which open directly into the liquid contents of any sump or pit shall employ a

slotted membrane fabric cover, or its equivalent, over at least 90 percent of the open area.

5. The perimeter of all fixed covers shall form a vapor-tight seal with the foundation to which it

is attached.

6. All rigid floating covers shall be installed and maintained such that the gap between the sump

or pit wall and the seal does not exceed 1 inch. Gap dimensions are perpendicular to the wall

of the sump or pit.

7. All pressure vacuum relief valves shall be set to within 10 percent of the maximum design

working pressure of the cover.

8. A flexible floating cover shall completely cover the sump.
Santa Barbara County APCD Rule 344 344 - 4 November 10, 1994

F. Requirements - Operator Inspection and Maintenance

1. The operator of any air pollution reduction control devices required in this rule shall inspect

them for defects every other calendar quarter.

2. Defects detected through either operator inspection or District inspection shall be repaired or

rectified within seven calendar days of detection. The operator shall reinspect and confirm

compliance of the repaired or replaced component within 15 calendar days after the repair or

replacement.

G. Requirements - Recordkeeping

1. The following information relating to inspection of sumps and pits shall be recorded for each

inspection:

a. the inspection date,

b. the nature of the inspection or test, with standardized methods specified,

c. the name of the person and company performing the test or inspection,

d. the findings, and

e. for each defect,

1) the type of defect and equipment which it affects,

2) the corrective action(s) taken,

3) the date and method by which compliance was confirmed, and

4) if a lack of vapor-tightness was detected, the concentration of total gaseous

hydrocarbons on which the lack of vapor-tightness is based and the

background concentration of total gaseous hydrocarbons.

2. The following information relating to detection of conditions requiring pumping of a well

cellar as required in Section D.3.c shall be recorded for each detection:

a. the date of the detection,

b. the name of the person and company performing the test or inspection, and

c. the date and time the well cellar is pumped.

3. An owner or operator claiming exemption B.3.a.1) shall perform a test at least once per year

on a date selected by the district. Copies of the lab results showing ROC concentrations of the

liquid entering and the liquid exiting the sump, the volume of liquid entering the sump during

the month the samples where taken, and the resulting ROC loss, shall be submitted to the

district for approval.

4. Owners or operators claiming an exemption per Section B.3.a.2) shall maintain records of the

volume of oil produced each month and the number of days that oil was produced.
Santa Barbara County APCD Rule 344 344 - 5 November 10, 1994

5. Owners or operators claiming an exemption per Section B.3.b. shall maintain records which

show each day the pit was used during each calendar year. These records shall be updated

daily during periods of sump use.

6. Owners or operators claiming an exemption per Section B.6 shall make production records

available for each well for which the exemption is claimed.

7. All records required by this Rule shall be maintained at the facility for a period of three years

after the end of each calendar year and made available to the District upon request.

H. Requirements - Sampling and Calculations

1. Sampling related to the exemption provided in Section B.3.a.1) shall be done annually on a

date chosen by the District. Samples shall be taken according to ASTM 4057 88. In the event

sampling and subsequent testing shows a facility no longer qualifies for this exemption,

facilities that have successfully demonstrated exempt status for the previous three years may

have one retest on a date chosen by the District.

2. Overall efficiency shall be calculated by multiplying the capture efficiency by the control

efficiency and expressing the result as a percentage.

3. Control efficiency as required by Sections D.2.b.2) or D.2.b.3) shall be calculated by dividing

the difference between control device inlet and exhaust quantities of total gaseous

hydrocarbons, excluding methane, by said inlet quantity. However, if the control device is a

thermal oxidizer, the control efficiency may be calculated according to 40 CFR 60.113b.c.1.i.

4. Calculations of monthly ROC emissions for the purpose of determining a Section B.3.a.1)

exemption shall be performed as follows:

Monthly ROC = V (ROCinlet - ROCoutlet)

where: V is the Volume of wastewater through the sump during the month that

wastewater was sampled for ROC content

ROCinlet is the concentration of ROC in liquid to enter the sump or pit

ROCoutlet is the concentration of ROC in liquid leaving the sump or pit

5. Any margin of error associated with a test method or protocol shall not be incorporated into

the results of any test.

I. Requirements - Test Methods

1. Capture efficiency as required to determine overall control efficiency shall be determined

using method specified in 55 Federal Register 26865, June 29, 1990.

2. For the purpose of determining applicability of Section B.3.a.1), concentration of ROC in

liquid shall be determined using purge and trap (EPA Method 5030) and extraction (EPA

Method 3510) with gas chromatograph mass spectroscopy. Stock standards shall be prepared

using crude oil or other fluids as appropriate.

3. To determine cover material adequacy, impermeability to ROCs shall be determined using

ASTM F119-82. Manufacturer's written certification of impermeability, where based on these

methods, is sufficient.
Santa Barbara County APCD Rule 344 344 - 6 November 10, 1994

4. For the purpose of determining control efficiency as required in section D.2.b.3), total gaseous

hydrocarbon concentration shall be determined using US EPA Test Method 25A and vapor

flow through pipes shall be determined using US EPA Test Method 2A, 2B, 2C, or 2D, as

appropriate.

5. Vapor-tightness shall be determined using US EPA Test Method 21. The analyzer shall be

calibrated with methane. If the alternative screening procedure referenced in Method 21 is

used and bubbles are observed, the instrument technique specified in Method 21 shall be used

within the same working day to determine vapor-tightness.

6. An alternate test method that is comparable in accuracy to the cited method may be used in

place of the above specified methods. The alternate method must be approved by the Control

Officer, CARB and USEPA.

J. Compliance Schedule

1. Owners and operators with well cellars and well heads subject to this rule shall operate them in

full compliance with this rule by April 30, 1996.

2. Sumps and pits with surface areas greater than or equal to 2000 square feet are subject to the

following compliance schedule:

a. an application for an Authority to Construct emission reduction equipment for an

existing sump or pit shall be submitted not later than October 30, 1995.

b. any person requesting an exemption per Section B.3.a.1), B.3.a.2), or B.3.b shall

submit documentation to the District that demonstrates their exempt status no later

than October 30, 1995. This documentation shall be provided in a format provided

by the District. Exemption requests submitted in any other format will be subject to

the cost reimbursement provisions of Rule 210.

c. shall be in full compliance no later than April 30, 1996.

3. Sumps and pits with surface areas less than 2000 square feet are subject to the following

compliance schedule:

a. an application for an Authority to Construct emission reduction equipment for an

existing sump or pit shall be submitted not later than October 30, 1997.

b. any person requesting an exemption per Section B.3.a.1), B.3.a.2), or B.3.b shall

submit documentation to the District that demonstrates status no later than October

30, 1997. This documentation shall be provided in a format provided by the District.

Exemption requests submitted in any other format will be subject to the cost

reimbursement provisions of Rule 210.

c. shall be in full compliance no later than April 30, 1998.

4. The owner or operator of any facility that claims exemptions B.3.a.1), B.3.a.2), or B.3.b shall

submit an application for an Authority to Construct within 90 days after the expiration of the

exemption and be in full compliance within 12 months of same.