SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX C: RACT Analysis June 16, 2011

Final Draft Staff Report with Appendices For Proposed Amendments to Ru le 4401 C - 1 

## APPENDIX C

Reasonably Available Control Technology

(RACT) Analysis

June 16, 2011SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

APPENDIX C: RACT Analysis June 16, 2011

Final Draft Staff Report with Appendices For Proposed Amendments to Ru le 4401 C - 2 This page intentionally blank.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

APPENDIX C: RACT Analysis June 16, 2011

Final Draft Staff Report with Appendices For Proposed Amendments to Ru le 4401 C - 3 I. REQUIREMENTS OF ANALYSIS

The Clean Air Act (CAA) Section 182(b)(2) states th at ozone attainment plans shall assure that RACT for volatile organic compounds (VO C) is applied at certain sources. A RACT analysis requires an examination of a rule a gainst Federal rules, regulations, and technology guidelines as well as comparing it a gainst rules from other Districts in California. District Rule 4401 was compared to fed eral and state regulations and guidance. The following is a discussion of that an alysis.

II. ANALYSIS

EPA – Control Technique Guidelines (CTG) There is no CTG for this source category.

EPA – Alternative Control Technology (ACT) There is no ACT for this source category.

Standards of Performance for New Stationary Sources (NSPS) There is no NSPS for this source category.

National Emission Standards for Hazardous Air Pollu tants (NESHAPs) and Maximum Achievable Control Technologies (MACTs) There is no NESHAP or MACT for this source category

.

How does District Rule 4401 compare to rules in oth er air districts? District staff compared control requirements, and w ork practice standards in District Rule 4401 to comparable requirements in rules from the following California

nonattainment areas: • South Coast AQMD Rule 1148, as amended November 5 , 1982. • Bay Area AQMD, Sacramento Metropolitan AQMD, and Ventura County APCD do not have a prohibitory rule that covers the same emissi on source category.

South Coast AQMD Rule 1148 South Coast AQMD Rule 1148 (Thermally Enhanced Oil Recovery Wells) requires that

ROG emissions from a steam drive well not to exceed 4.5 lb/day or if steamed drive wells are connected to vapor control system ROG emi ssions from the control system shall average no more than 4.5 lb/day/connected wel l. Using CARB emissions factor for uncontrolled steam drive well of 220 lb-VOC/day , Rule 4401’s 99% control requirement equates to 2.2 lb/day/well, which is mo re stringent than 4.5 lb/day/well (heavy oil production results in no methane or etha ne, meaning 100% of ROGs are considered VOCs).

South Coast AQMD Rule 1148 does not specify any fug itive VOC leak detection and repair provisions where as Rule 4401 specifies the number of allowable componentSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

APPENDIX C: RACT Analysis June 16, 2011

Final Draft Staff Report with Appendices For Proposed Amendments to Ru le 4401 C - 4 leaks based on the number of wells connected to a v apor collection and control system. Rule 4401 requires an operator, upon detection of a leak, to affix a readily visible tag bearing the date on which the leak is detected. Ru le 4401 further requires an operator to repair a leak within fifteen (15) calendar days; failure to repair the leak would

constitute a violation of the rule.

South Coast AQMD Rule 1148 contains a six month exe mption for steam drive wells if steam is injected more frequently than 45 days and amount of steam injection expressed as water is more than 2,000 barrels. Rule 4401 provides exemptions for up to 40 cyclic wells owned by a company that are unde rgoing pilot testing and well stimulation. Rule 4401 also exempts for up to 5 cyc lic wells (20 cyclic wells for small producer) if wells are located more than 1000 feet from an existing well control system operated by the company and operation is under Dist rict permit. South Coast AQMD

Rule 1148 does not limit number of wells that can b e exempt and Rule 4401 does not limit duration of exemption, therefore exemptions i n the both rules can not be compared directly.

Both South Coast AQMD Rule 1148 and Rule 4401 requi re annual testing of vapor control systems. However, District Rule waives this testing requirement if uncondensed vapors are incinerated in fuel burning equipment, i nternal combustion engine or in a

smokeless flare.

III. RESULTS OF ANALYSIS

After careful evaluation of federal rules and regul ations as well as prohibitory rules in other California nonattainment areas, District staf f concludes that District Rule 4401 satisfies RACT for steam-enhanced crude oil product ion well vents.