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SJVAPCD Adopted Rule Changes – Fall 2023

September 26, 2023

In June 2023, the San Joaquin Valley Air Pollution Control District (SJVAPCD) adopted amendments to the following rules to address Best Available Retrofit Control Technology (BARCT) and the United States Environmental Protection Agency’s (U.S. EPA’s) 2016 Control Techniques Guidelines (CTG) and establish more stringent leak detection and repair (LDAR) requirements for volatile organic compound (VOC) emissions from components associated with the production of oil and gas.

• Rule 4401: Steam-Enhanced Crude Oil Production Wells;
• Rule 4409: Components at Light Crude Oil Production Facilities, Natural Gas Production Facilities, and Natural Gas Processing Facilities;
• Rule 4455: Components at Petroleum Refineries, Gas Liquids Processing Facilities, and Chemical Plants; and
• Rule 4623: Storage of Organic Liquids, and Rule 4624: Transfer of Organic Liquid.

In general, the revised LDAR requirements begin after June 30, 2024, and include:

• The definition of a minor gas leak for components other than pressure relief devices was typically lowered to 500 parts per million by volume (ppmv) as methane;
• Generally, the component leak inspection frequency was modified to require quarterly inspections;
• In some cases, the number of allowable leaks identified during inspections was reduced;
• The allowable repair period for leaks was reduced to as short as 1 day;
• Rule 4401, 4409, and 4455 exemptions for ½-inch or smaller stainless steel tube fittings have been removed;
• For Rules 4401, 4409, and 4455, procedures are specified to request an extended repair period in the event a rig-up operation is required to complete the repair; and
• Leaks detected by optical gas imaging (OGI) must be measured by U.S. EPA Method 21 to determine compliance with leak thresholds and repair timeframes.

Amendments to Rule 4623 may require additional VOC control systems. Tanks storing organic liquids with a true vapor pressure (TVP) of ≥0.1 pound per square inch absolute (psia) and <0.5 psia will require a pressure-vacuum release valve. Tanks with a potential to emit (PTE) of 6 tons per year (TPY) and actual emissions greater than 4 TPY will require a vapor control system if one is not already installed. For tanks required to install a VOC emission control device (including a pressure-vacuum relief valve), a permit application is due by March 31, 2024.

The Rule 4623 amendments also include new tank inspection requirements and leak repair timeframes as specified in Section 5.9. Pressure vessels, gasoline storage tanks <19,800 gallons, wine and spirits storage tanks, and clean-produced water storage tanks (with a PTE ≤6 TPY) are exempt from the requirements of Rule 4623.

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