SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix C: Rule Consistency Analysis December 15, 2011

C - 1 Final Staff Report with Appendice s for Revised Proposed Amendments t o Rule 4402 

## APPENDIX C

Rule Consistency Analysis For Revised Proposed Amendments to Rule 4402

December 15, 2011SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix C: Rule Consistency Analysis December 15, 2011

C - 2 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4402 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix C: Rule Consistency Analysis December 15, 2011

C - 3 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4402 

### RULE CONSISTENCY ANALYSIS FOR

REVISED PROPOSED AMENDMENTS TO RULE 4402

I. REQUIREMENTS FOR RULE CONSISTENCY 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 the rule or regulation with corresponding elements of existing or proposed District and United States Environmental Protection Agency (EPA) rules, regulations, and guidelines that apply to the same source category. The elements an alyzed are emission standards, monitoring and testing, and recordkeeping and repor ting requirements.

II. RULE CONSISTENCY ANALYSIS

A. District Rules

Facilities subject to District Rule 4402 could be s ubject to other District rules including:

 Rule 2201 New and Modified Stationary Source Revie w
 Rule 2020 Exemptions

 Rule 2520 Federally Mandated Operating Permits

 Rule 4001 New Source Performance Standards

 Rule 4002 National Emissions Standards for Hazardo us Air Pollutants

 Rule 4101 Visible Emissions

 Rule 4102 Nuisance

 Rule 4455 Components at Petroleum Refineries, Gas Liquids

Processing Facilities, and Chemical Plants

 Rule 4623 Storage of Organic Liquid

 Rule 4625 Wastewater Separators

The above-listed rules are not in conflict with, no r are they inconsistent with the requirements of Revised Proposed Rule 4402.

B. Federal EPA Rules and Regulations

1. EPA “Alternative Control Techniques (ACT) Docume nt

District staff’s review of the EPA ACT list indicat es that there is no ACT for crude oil production sumps.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix C: Rule Consistency Analysis December 15, 2011

C - 4 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4402 2. EPA “Control Techniques Guideline (CTG) Document

District staff’s review of the EPA CTG list indicat es that there is no CTG for crude oil production sumps.

3. National Emission Standards for Hazardous Air Po llutants (NESHAPs) and Maximum Achievable Control Technologies (MACTs)

District staff’s review of 40 CFR 61 (NESHAP) and 4 0 CFR (NESHAP for Source Categories) indicates that there is no NESHAP or MA CT for crude oil production

sumps.

4. EPA Policy on Recordkeeping

The recordkeeping requirement in Section 6.0 of Rul e 4402 is consistent with EPA’s policy to keep and maintain records for at le ast five years.

III. CONCLUSION

Based on the above analysis, District staff found t hat the revised proposed amendments to Rule 4402 would not conflict with federal rules, regulations, or policies covering similar stationary sources.