MEMORANDUM
DATE: January 30, 2024
TO: Camarillo City Council
FROM: Kirsten Marble
SUBJECT: Report on the Activities of the Ventura County Air Pollution Control District (VCAPCD) Advisory Committee in 2023
The VCAPCD Advisory Committee met three times in 2023 to review proposed amendments to the VCAPCD Rules and Regulations and make recommendations to the VCAPCD Board. The City of Camarillo representative, Kirsten Marble, was in attendance at all meetings and voted in favor of all proposed amendments. The Advisory Committee recommended approval of all proposed amendments, and all amendments were approved by the Board.
The approved amendments and other activities of the Advisory Committee are summarized below.
June 27, 2023 Meeting
1. Election of Officers
The Advisory Committee voted unanimously to reelect Sara Head as Chair of the Advisory Committee and reelect Paul Meehan as Vice Chair of the Advisory Committee.
2. Proposed Amendments to Rule 71.1 Crude Oil Production and Separation VCAPCD staff proposed amendments to Rule 71.1 to correct deficiencies identified by the Environmental Protection Agency (EPA) and to make the rule consistent with other District rules and with the EPA’s Control Techniques Guidelines (CTG) for the Oil and Gas Industry. These proposed amendments were administrative in nature and would not provide measurable emissions reductions.
Staff held a public workshop on June 6, 2023, to solicit public input on the proposed amendments and received no substantive comments.
Recommended for approval, approved by the Board on July 11, 2023
3. Proposed New Rule 74.35 Flares
VCAPCD staff proposed new Rule 74.35 to reduce the emissions of reactive organic compounds (ROC) and oxides of nitrogen (NOx) from flares with a rated heat input rating of 1 million British thermal units (Btu) and greater. Staff estimated that four existing oil field flares combusting produced gas may require replacement based on an analysis of the proposed rule requirements. This would reduce NOx emissions by approximately 6.9 tons and would reduce ROC emissions by approximately
6.1 tons. The cost-effectiveness of the combined emissions reductions was estimated to be $27,913 per ton which is below the Best Available Retrofit Control Technology (BARCT) cost effectiveness
threshold of $30,000 per ton set by the Board. Staff held an initial public workshop for Rule 74.35 on May 13, 2022, and engaged extensively with the regulated community in the following year to address their concerns and develop rule requirements that would be effective in reducing emissions while not being overly burdensome to the regulated community. Staff held another public workshop on June 6, 2023, during which the regulated community expressed support for Rule 74.35.
Recommended for approval
August 15, 2023 Meeting
1. Proposed Revisions to New Rule 74.35 Flares
VCAPCD staff previously brought the proposed new Rule 74.35 before the Advisory Committee on June 27, 2023. On July 5, 2023, staff received comments from Clean Water SoCal, representing wastewater treatment plants in Ventura County that have digester gas flares. They had concerns about the cost-effectiveness of requiring minor source flares to meet major source BARCT emissions limits.
Staff reviewed the information provided by Clean Water SoCal and determined it was appropriate to revise Rule 74.35 to include minor source limits. Staff also made clarifying edits to the periodic reporting requirements on the advice of District Counsel.
Recommended for approval, approved by the Board on September 12, 2023 November 30, 2023 Meeting (rescheduled from November 14, 2023 due to lack of quorum)
1. Proposed Amendments to Rule 74.10 Components at Crude Oil and Natural Gas Production and Processing Facilities
VCAPCD staff proposed extensive amendments to Rule 74.10 to reduce the emissions of ROC and methane from equipment leaks by enhancing the inspection and maintenance program at crude oil and natural gas production and processing facilities. The primary driver of emission reductions was the proposed change to the definition of a minor gas leak from 1,000 parts per million by volume (ppmv) of organic gas as methane to 500 ppmv of organic gas as methane. The proposed amendments were based on similar standards required by the San Joaquin Valley Air Pollution Control District, the California Air Resources Board’s Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities Regulation, and the EPA CTG for the Oil and Gas Industry. Staff estimated that the proposed amendments would reduce ROC emissions by approximately 40 tons per year with an estimated cost-effectiveness of $30,526 per ton, which slightly exceeds the BARCT cost- effectiveness threshold of $30,000 per ton. Staff held a public workshop for the proposed amendments and also received written comments from the Western States Petroleum Association (WSPA), dated September 27, 2023. Staff had multiple discussions with WSPA staff and members to address their comments and work out mutually acceptable resolutions.
Recommended for approval, approved by the Board on December 12, 2023
2. Proposed Amendments to Rule 71 Crude Oil and Reactive Organic Compound Liquids VCAPCD staff proposed amendments to Rule 71 to ensure definitions are consistent across all District rules that apply to oil and gas production and processing facilities. These proposed amendments were administrative in nature and would not provide measurable emissions reductions.
Staff held a public workshop to solicit public input on the proposed amendments and received no comments.
Recommended for approval, approved by the Board on December 12, 2023