VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT


Rule 74.10 - Components at Crude Oil and Natural Gas Production and Processing Facilities. (Adopted 9/29/81, Revised 9/22/87, 5/28/91, 6/16/92)

A. Applicability

The following provisions shall apply to crude oil production and processing facilities, and natural gas production and processing facilities.

B. Operating Requirements

  1. Hatches shall be closed at all times except during sampling or attended maintenance operations.

  2. No person shall use a component at a crude oil or natural gas production facility, or a natural gas processing plant if such component leaks (as defined in Subsection J.9) reactive organic compounds when the applicable maximum leak threshold for that component category as listed in Attachment 1 has been exceeded at the facility after the applicable effective date in any calendar quarter. The provisions of this subsection shall not apply to components that are tagged and repaired in accordance with Sections C and E of this Rule.

  3. The following operating requirements shall only apply to natural gas processing plants, except for those plants that are less than 10MM scfd (283,000 scmd) capacity and do not fractionate natural gas liquids:

  4. a. Each open ended line or valve that has the potential to emit vapors shall be sealed with a second valve, a blind flange, a cap or a plug. The open end shall be sealed at all times except during operations requiring process fluid flow through the open-ended valve or line.

    b. Each open-ended valve or line equipped with a second valve shall be operated in a manner such that the valve or process fluid end is closed before the second valve is closed. When a double block-and-bleed system is being used, the bleed valve or line may remain open during operations that require venting the line between the block valves.

    c. A pressure relief device shall be inspected within 14 calendar days after every functional pressure relief.

C. Operator Inspection Requirements

  1. Operators shall visually inspect pumps, including but not limited to rod pumps and compressor pumps, not less than weekly for liquid leaks.

  2. Operators shall monitor the following components at least every calendar quarter for gaseous leaks in accordance with EPA Reference Method 21. All other components not listed below, except flanges designated in the Operator Management Plan as exempt from inspection requirements, shall be monitored at least annually in accordance with EPA Reference Method 21:

  3. a. Valves.

    b. Packing seals on dump lever arms connected to gas traps, separators, or vessels.

    c. Hatches on non vapor recovery tanks.

    d. Polished rod stuffing boxes.

    e. At natural gas processing plants: compressor seals, pressure relief devices, and pumps.

  4. Upon detection, operators shall affix a readily visible tag to all leaking components with the date that leaks are detected. The tag shall remain affixed until the component is repaired free of leaks as shown by re-inspection.

  5. Notwithstanding the requirements of Subsection C.2, operators may monitor annually instead of quarterly by doing the following, except that three types of natural gas processing plant components (compressors, pressure relief devices, and pumps) shall not be eligible for this reduction in monitoring frequency.

  6. a. Achieve a "good performance level" as defined in Subsection J.6 for five consecutive quarters, and

    b. Request the District, in writing, for a reduction in monitoring frequency. This request must contain backup documentation including inspection reports that demonstrates that good performance level has been achieved. Requests for a reduction in monitoring frequency are not effective until written approval by the APCO is received by the operator.

  7. Quarterly monitoring shall be reinstated by the operator during the next calendar quarter upon failure to achieve a "good performance level".

D. Operator Management Plan Requirements

  1. Each operator shall submit a Management Plan, to the APCO for approval. If the APCO fails to respond to the Plan in writing within 90 days after it has been received, then it shall be deemed approved. No provision in the Plan, approved or not, shall conflict with or take precedence over any provision of this rule. The Operator Management Plan shall identify any component exempt from this rule or part of this rule, and describe the procedures which the operator intends to use to comply with the requirements of this rule. The Management Plan must identify:

  2. a. Any component for which exemption is being claimed under Subsection F.2.a, that is located such that monitoring personnel must be elevated two (2) or more meters above permanent support surfaces or require scaffolding, or is located such that inspection would be infeasible or unsafe for personnel

    b. Any critical process units

    c. Any components for which exemption is being claimed under Section F of this Rule. Gaseous streams and liquid streams, exempted by Subsections F.1.a, F.1.b or F.1.c, must be verified by analysis of the ROC concentrations

    d. Any heavy liquid service stream for which exemption is being claimed from the operator inspection requirements (Subsection F.2.b). Such streams must be verified by analysis, and

    e. Whether flanges are exempt from all inspection requirements and subject to a zero leak threshold or whether flanges are subject to annual inspection requirements and a 1 percent leak threshold as specified in Attachment 1.

  3. For new facilities or modifications to a facility covered under an existing Plan, the operator shall submit a new or modified Plan to the APCO for approval with the application for a Permit to Operate. If the APCO fails to respond to the Plan in writing within 90 days after it has been received, then it shall be deemed approved. No provision in the Plan, approved or not, shall conflict with or take precedence over any provision of this rule.

  4. The operator shall be required, upon written request by the APCO, to re-qualify, by analysis, the exemption(s) from the rule or part of the rule (Subsections F.1.a, F.1.b, F.1.c and F.2.b) if the exemption(s) may no longer be valid based on the changed composition of the process stream. The results of that analysis and any modification to the Plan shall be submitted to the District within 90 days after receipt of the District request.

  5. If the exempt status of a component is affected by a revision to this rule, then the Plan shall be modified accordingly. The modification to the Plan shall be submitted to the District no later than 90 days after adoption of the rule revision.

E. Operator Repair Requirements

  1. Any component found leaking shall be repaired to a leak free condition, except as provided in the following Subsection E.2, and:

  2. a. At a natural gas processing facility, no later than 15 days from the detection date.

    b. At any other facility, as soon as practicable but no later than 21 days from the detection date.

  3. A leaking component which is an essential part of a critical process unit identified in an approved Management Plan must be repaired during the next scheduled shutdown or process turnaround of the unit, but not later than three (3) months from the date of detection.

  4. The operator shall re-inspect components for leaks as soon as practicable, but not later than one week after the date on which the component is repaired.

  5. Any component leak identified by the District shall be repaired and inspected as required by Section E.

F. Exemptions

  1. The requirements of this rule shall not apply to:

  2. a. Components, not at natural gas processing plants, with gaseous streams with ROC concentrations of 12% by weight or less.

    b. Any component at a natural gas processing plant with gaseous streams with ROC concentration, less the ethane concentration, equal to or less than 1% by weight.

    c. Components, except for components at natural gas processing plants, in liquid service, with ROC concentrations of 12% by weight or less.

  3. The operator inspection requirements of Section C shall not apply to the following components. All other requirements of this rule shall still apply.

  4. a. Any component that is located such that monitoring personnel must be elevated two (2) or more meters above permanent support surfaces or require scaffolding, or is located such that inspection would be infeasible or unsafe for personnel, is exempt from quarterly monitoring requirements. Such component shall be inspected at least annually. Components may be considered unsafe to monitor, if monitoring personnel would be exposed to an immediate danger as a consequence of carrying out an inspection.

    b. Any component, except for a component at a natural gas processing plant, that is in heavy liquid service.

    c. Flanges that are designated in the Operator Management Plan as subject to the zero leak threshold specified in Attachment 1.

G. Recordkeeping Requirements

  1. Any person subject to the requirements of this Rule shall maintain an inspection log containing, at a minimum, the following:

  2. a. Location, type, description of each leaking component inspected, and name of any operating unit where each leaking component is found

    b. Date of leak detection and method of detection

    c. Date that leak is repaired to a leak free condition, and date of re-check

    d. Identification of leaks from critical process units

    e. Number of components inspected, number and percentage of leaking components found, categorized by the following groups:

      1) Hatches

      2) Polished rod stuffing boxes

      3) Dump lever arms

      4) Valves (not open ended)

      5) Open ended lines

      6) Flanges (if designated in Operator Management Plan as exempt from inspection requirements)

      7) Other components

  3. The operator of any natural gas processing plant subject to the requirements of Subsection B.3 shall record the following information in addition to what is required by Subsection G.1:

  4. a. Location, operating unit, type, and description of each pressure relief device where a functional pressure relief has occurred and the date of that occurrence.

    b. Date of inspection of the pressure relief device in Subsection G.2.a.

  5. Copies of the inspection log shall be retained by the operator for a minimum of 2 years after the date of an entry.

  6. Copies of the inspection log shall be made available upon request to District personnel.

H. Test Methods

  1. Gaseous leaks from components shall be determined by EPA Method 21 by using an appropriate analyzer calibrated with methane. The calibration, maintenance, and operation of the appropriate analyzer shall follow the manufacturer's recommendations.

  2. The ROC concentration, by weight, of gaseous process streams shall be measured by ASTM E168-67 (General Techniques of Infrared Qualitative Analysis), ASTM E169-63 (General Techniques of Ultraviolet Quantitative Analysis), or ASTM E260-73 (Gas Chromatography), or updated versions of these methods approved by EPA and published in the 40 CFR Part 60.

  3. The ROC concentration, by weight, of liquid process streams not at natural gas processing plants, shall be measured using ASTM Method D96 (Water Cut and Sediment). The ROC concentration of the liquid shall be the material remaining after separating the water and sediment.

  4. The API gravity of crude oil shall be determined using ASTM Method D287.

I. Violations

The failure of a person to meet any requirements of this rule shall constitute a violation of this rule. Each leak exceeding the applicable maximum leak threshold in Attachment 1 discovered by District personnel will be considered to be a violation.

J. Definitions

  1. "Appropriate Analyzer": A hydrocarbon analyzer that meets the requirements of EPA Reference Method 21 and is calibrated with methane.

  2. "Component": Any valve, connection, diaphragm, open ended line, flange, pressure relief device, seal packing, sealing mechanism, hatch, sight glass, meter, pump, or other fugitive emission source.

  3. "Critical Process Unit": Any process unit that has no standby equipment available, that cannot be bypassed, and that would be technically infeasible to repair leaks from that process unit without shutting it down.

  4. "Crude Oil Production and Processing Facility": Any facility where crude oil production and processing are conducted as defined in the Standard Industrial Classification Code 1311.

  5. "Facility": A facility is any "stationary source" as defined in Rule 2 of these rules.

  6. "Good Performance Level": A "Good Performance Level" can be accomplished by having components not exceed any of the maximum leak rates as listed in Attachment 1, Component Leak Rate Thresholds and not receiving a Notice of Violation from the District for violation of Subsection B.2 of this rule.

  7. "Heavy Liquid Service": Any component handling crude oil at 20o API gravity or less, will be considered in "heavy liquid service".

  8. "Inspections:"

  9. a. "Operator Inspection": A survey by the operator of components to detect leaks in accordance with EPA Reference Method 21 and repair leaks for the purposes of complying with this rule.

    b. "District Inspection": A survey of components to detect leaks in accordance with EPA Reference Method 21 by APCD personnel for enforcement purposes.

  10. "Leak":

  11. a. A leak exists when the dripping at a rate of more than three (3) drops per minute of liquid containing reactive organic compounds is observed; or

    b. An emission of gaseous reactive organic compound which causes an appropriate analyzer sampling one (1) centimeter from a source to register at least 10,000 ppmv, as methane, as determined by EPA Reference Method 21, except from pressure relief devices (including hatches on non-vapor recovery tanks that serve the purpose of pressure relief devices) when the process pressure exceeds the limit setting specified for the device and except from pneumatic control valves during the bleeding of gas only during valve actuation.

  12. "Liquid Service": Any component handling water or any petroleum product solely in liquid state at process conditions.

  13. "Natural Gas Processing Plant": A facility engaged in the separation of natural gas liquids from field gas and/or fractionation of the liquids into natural gas products, such as ethane, propane, butane, and natural gasoline. Excluded from the definition are compressor stations, dehydration units, sweetening units, field treatment, underground storage facilities, liquified natural gas units, and field gas gathering systems unless these facilities are located at a natural gas processing plant.

  14. "Notice of Violation": An official notice to an operator for violating a requirement of this rule which may result in District enforcement action.

  15. "Open ended line": Any valve, except safety relief valves, having one side of the valve seat in contact with the process fluid and one side open to the atmosphere.

  16. "Reactive Organic Compound (ROC)": Any reactive organic compound as defined in Rule 2 of these rules.

  17. "Valve": Any device that regulates the flow of fluid in a piping system by means of an external actuator acting to permit or block passage of fluid excluding the attached flange and the flange seal.


ATTACHMENT 1

COMPONENT LEAK THESHOLDS

This Attachment defines the leak thresholds for the operating requirements in Subsection B.2, and for the definition of "good performance level", as defined in Subsection J.6.

COMPONENT NO. OF COMPONENTS INSPECTED MAXIMUM NUMBER OF LEAKS EFFECTIVE DATE
Hatches 0 9/22/87
Open Ended Lines 0 9/22/87
+Flanges (If designated in the Operator Management Plan as exempt from inspection requirements) 0 9/22/87
Valves (not open ended) 250 or less

More than 250

5

2% of number of components inspected

9/22/87

9/22/87

Other Components+ 250 or less

More than 250

2

1% of number of components inspected

9/22/87

9/22/87

+ Other components in Attachment 1 are all components (including flanges not exempt from operator inspection requirements) except polished rod stuffing boxes, dump lever arms, hatches, valves, open ended lines, and flanges exempt from operator inspection requirements.