PROPOSED June 16, 2011 

   Proposed Rule 4401

RULE 4401 STEAM-ENHANCED CRUDE OIL PRODUCTION WELLS (Adopted April 

11, 1991; Amended September 19, 1991; Amended December 17, 1992; 

Amended January 15, 1998; Amended December 14, 2006, Amended [Rule 

Adoption Date]) 

1.0 Purpose 

The purpose of this rule is to limit the Volatile Organic Compound (VOC) emissions from 

steam-enhanced crude oil production wells. 

2.0 Applicability 

This rule is applicable to all steam-enhanced crude oil production wells and any associated 

VOC vapor collection and control systems. 

3.0 Definitions 

3.1 Air Pollution Control Officer (APCO): as defined in Rule 1020 (Definitions). 

3.2 Background: a reading on a portable hydrocarbon detection instrument which is 

determined at a distance no greater than two (2) meters upwind from any 

component to be inspected and which is not influenced by any specific emission 

point. 

3.3 Component: includes, but is not limited to, any valve, fitting, threaded 

connection, pump, compressor, pressure relief device, pipe, flange, process 

drain, sealing mechanism, hatch, sight-glass, meter, or seal fluid system in VOC 

service. 

3.4 Component Type: includes, but is not limited to, any one (1) of the following 

groups: valves, fittings, threaded connections, pumps, compressors, pressure 

relief devices, pipes, flanges, process drains, sealing mechanisms, hatches, 

sight-glasses, meters, or seal fluid systems in VOC service. 

3.5 Compressor: a device used to compress gases or vapors or a combination of 

gases and vapors by the addition of energy, and includes all associated 

components used for connecting and sealing purposes. The phrase "all 

associated components used for connecting and sealing purposes" means the first 

VOC leak points (first components) connected on the body of the compressor. 

For example, a valve that is connected to a threaded hole on the body of the 

compressor, the first VOC leak point is the threaded connection on the body 

side of the compressor, but the valve itself is not a "first VOC leak point". 

Similarly, a compressor shaft seal is considered as a “first VOC leak point”. 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

3.6 Critical Component: a component that would require the shutdown of a critical 

process unit if that component was shut down or disabled. 

3.7 Critical Process Unit: a process unit that must remain in service because of its 

importance to the overall process that requires it to continue to operate, and has no 

equivalent equipment to replace it or cannot be bypassed, and it is technically 

infeasible to repair leaks from that process unit without shutting it down and 

opening the process unit to the atmosphere. 

3.8 Critical Process Unit Shutdown: the shutdown of a critical process unit or part of 

the critical process unit that causes the entire unit to cease operating. 

3.9 Cyclic Well: for purposes of this rule, any crude oil production well, which is 

periodically (at least once in the preceding two (2) year period) injected with 

steam from any source for the purpose of enhancing oil production. 

3.10 District: San Joaquin Valley Unified Air Pollution Control District, or any person 

designated to act on its behalf. 

3.11 EPA: United States Environmental Protection Agency, or any person designated 

to act on its behalf. 

3.12 Essential Component: a component that cannot be taken out of service without 

reducing, by more than 33 percent, the throughput of the process unit that it 

serves. 

3.13 Facility: a stationary source as defined in Rule 2201 (New and Modified 

Stationary Source Rule). 

3.14 Fitting: a component, excluding flanges and threaded connectors, used to attach 

or connect pipes or piping system. Examples of a “fitting” include, but are not 

limited to quick-disconnect fittings, push-in-fittings, and cam-locks. 

3.15 Front Line Production Equipment: a tank or vessel in which any organic liquid 

is placed, held, or stored and that is the first vessel that receives crude oil/fluids 

directly from wells subject to this rule including, but is not limited to, wash 

tanks, free water knockouts, separators, etc., and that is operating under 

atmospheric or near atmospheric pressure. After production is routed through at 

least one of such tanks or vessels, downstream vessels are no longer considered 

front line production equipment. A gauge tank, as defined in Section 3.0 of this 

rule, shall not be considered as Front Line Production Equipment. 

3.16 Fuel Burning Equipment: as defined in Rule 1020 (Definitions). 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

3.17 Gauge Tank: for the purposes of this rule only, a tank which is used exclusively 

for measuring the amount of produced fluid produced by an oil well(s) and meets 

all the following conditions: 

3.17.1 Has a capacity of 100 barrels (4,200 gallons) or less, 

3.17.2 Is in operation on or before December 14, 2006, 

3.17.3 Receives or stores produced fluid (crude oil or mixture of crude oil and 

water), 

3.17.4 Is connected to at least one steam-enhanced crude oil production well 

with a closed vent, 

3.17.5 Is upstream of all front line production equipment, 

3.17.6 Does not have its VOC emissions controlled to at least 99% and 

3.17.7 The true vapor pressure (TVP) of the produced fluid in the gauge tank, 

at all times, shall be less than 0.5 psia as determined pursuant to the 

provisions of Section 6.2.3 6.2.5. 

3.18 Inaccessible Component: a component that is located more than 15 feet above 

ground when access is required from the ground; or a component that is located 

more than six (6) feet away from a platform when access is required from the 

platform, or a component in a location that would require the elevation of 

monitoring personnel higher than six (6) feet above permanent support surfaces. 

3.19 Inspection: checking and/or testing in order to detect leaks. 

3.19.1 District Inspection: inspection of components by District personnel or 

their representative to insure facilities and/or operators are in compliance 

with District requirements. 

3.19.2 Operator Inspection: inspection of components conducted by the operator 

pursuant to the inspection and re-inspection schedules specified in this 

rule for the purpose of demonstrating compliance with this rule. 

3.20 Leak: 

3.20.1 Effective until December 31, 2008, a reading as methane on a portable 

hydrocarbon detection instrument (calibrated with methane) in excess of 

10,000 ppm when measured in accordance with the test method specified 

in Section 6.3.3. 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

3.20.2 Effective on and after January 1, 2009, the 

The dripping of VOC-containing liquid or the detection of a concentration of total 

organic compound, above background, determined according to the test method 

specified in Section 6.3.3 that exceeds any of the values specified in Table 1, 

Section 3.20.1 and Section 3.20.2 .2.1 and Section 3.20.2.2 of this rule. Any 

liquid or gas coming from a component undergoing repair or replacement, or 

during sampling of process fluid from a component into a container is not 

considered a leak provided such activities are done as expeditiously as possible 

and with minimal spillage of material and VOC emissions to the atmosphere. 

Table 1 Gas Lean in ppmv as Methane 

Type of Component Major Gas Leak Minor Gas Leak 

1. PRDs Greater than 10,000 400 to 10,000 

2. Components other than PRDs Greater than 10,000 2,000 to 10,000 

3.20.2.1 Major Liquid Leak: a visible mist or a continuous flow of 

liquid that is not seal lubricant. 

3.20.2.2 Minor Liquid Leak: a liquid leak, except seal lubricant, that is 

not a major liquid leak and drips liquid at a rate of more than three 

drops per minute. 

3.21 Leak Minimization: reducing a leak to the lowest achievable level without 

damaging the component using best modern practices which include, but are not 

limited to, adding sealing material to the component, tightening the component, 

or adjusting the component without shutdown of the process that the component 

serves and that can be safely accommodated. 

3.22 Major Component: any pump five (5) brake horsepower or larger, any 

compressor, or any pressure relief valve four (4) inches in diameter or larger. 

3.23 Open-ended Line or Valve: a line or valve, except PRD, having one side of the 

line or valve seat in contact with the process fluid and one side open to the 

atmosphere, either directly or through an open piping. 

3.24 Operate: to perform any activity with, or on any steam-enhanced crude oil 

production well, including but not limited to producing, steam-enhancing, venting, 

maintaining or repairing. 

3.25 Pilot Testing: testing of a new cyclic well for up to 180 days from each 

production zone for the purpose of determining the viability of developing a 

steam-enhanced production zone. 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

3.26 Portable Hydrocarbon Detection Instrument: a hand-held hydrocarbon analyzer 

that meets the criteria specified in EPA Method 21, 40 CFR Part 60. The 

instrument shall be calibrated on methane. 

3.27 Pressure Relief Device (PRD): a pressure relief valve or a rupture disk. 

3.28 Pressure Relief Valve (PRV): an automatic pressure-relieving device associated 

with a process vessel or piping system that is activated by pressure upstream of 

the device and relieves to the atmosphere (atmospheric PRV). 

3.29 Process Drain: any open portion of a non-continuous piping system, including 

open origination portion(s) of such a system used for collection and transport of 

liquids discharged from process vessels, spills, or other sources. Drain 

origination points and drain termination points are not open-ended lines. 

Process drains are not open-ended lines. 

3.30 Process System: an APCO-approved system that is not open to the atmosphere 

and is composed of hard-piping, ductwork connections and, if necessary, flow 

inducing devices that transport gases or vapors from a piece of equipment to a 

process stream, fuel gas system, sales gas system or an injection well approved 

by the Department of Oil, Gas, and Geothermal Resources (DOGGR). 

3.31 Process Unit: a manufacturing process which is independent of other processes 

and is continuous when supplied with a constant feed of raw material and 

sufficient storage facilities for the final product. 

3.32 Production Zone: a subsurface geologic formation or group of formations of oilbearing material through which steam could migrate from a steam injection well, 

or cyclic well being steamed to an oil production well. 

3.33 Pump: a device used to transport fluids by the addition of energy, and includes all 

associated components used for connecting or sealing purposes. The phrase "all 

associated components used for connecting and sealing purposes" means the first 

VOC leak points (first components) on the body of the pump. For example, a 

valve that is connected to a threaded hole on the body of the pump, the first 

VOC leak point is the threaded connection on the body side of the pump, but the 

valve itself is not a "first VOC leak point". Similarly, a pump shaft seal is 

considered as a “first VOC leak point”. 

3.34 Release: a VOC emission to the atmosphere from a PRD caused by an increase 

in upstream pressure. A leak caused by improper reseating of the PRD is not a 

release. 
 PROPOSED June 16, 2011 

  	 Proposed Rule 4401

3.35 Rupture Disk: a rigid diaphragm held between flanges for the purpose of isolating 

organic compounds from the atmosphere or from a downstream pressure relief 

valve. Rupture disks are designed to fail at a certain pressure point. 

3.36 Service or Repair: a well shall be considered under service or repair during rigup, operation, and rig-down of any rig or pulling unit used to repair or maintain 

surface or downhole well equipment. 

3.37 Sight glass: a device located on a fluid line or a process vessel that allows an 

operator to view the product or material inside a fluid line or a process vessel. 

3.38 Small Producer: a person who produces a monthly average of less than 6,000 

barrels of crude oil per day from all operations in any one county within the 

District, and who does not engage in refining, transporting, or marketing of 

refined petroleum products. An operator shall qualify as a small producer only in 

the county where the operator’s crude oil production does not exceed the threshold 

specified above. 

3.39 Steam Drive Well: any crude oil production well which produces from the same 

production zone in which a steam injection well is completed and is within: 

3.39.1 250 feet of a steam injection well, if the injection well is within a 

production well pattern of two and one-half (2 1/2) acres or smaller; or 

3.39.2 350 feet of a steam injection well, if the injection well is within a 

production well pattern of greater than two and one-half (2 1/2) acres but 

less than or equal to five (5) acres, or 

3.39.3 500 feet of a steam injection well, if the injection well is within a 

production well pattern larger than five (5) acres, or 

3.39.4 1000 feet of a steam injection well, and responds to steam injected in an 

irregular production well pattern, and exhibits any visible emissions. 

3.40 Steam-Enhanced Crude Oil Production Well: any steam drive well, cyclic well, 

or any other well in which the temperature of crude oil is raised, by the injection 

of steam, above the production zone temperature that existed prior to the injection 

of steam. 

3.41 Steam Injection Well: a well into which steam is injected that enhances the 

production of oil from other wells in the same production zone. Cyclic wells 

which enhance production of oil from other wells in the production zone are 

considered injection wells. 
 PROPOSED June 16, 2011 

  
 Proposed Rule 4401

3.42 Tag: a piece of paper, metal, plastic or other suitable material that is attached to a 

component for the purpose of identification or other information. 

3.43 True Vapor Pressure (TVP): as defined in Rule 4623 (Storage of Organic 

Liquids). 

3.44 Turnaround: a scheduled shutdown of a process unit for maintenance and repair 

work. 

3.45 Unsafe-to-Monitor Component: a component installed at a location that would 

prevent the safe inspection or repair of a component as defined by OSHA 

standards or in provisions for worker safety stated in 29 CFR 1910. 

3.46 Vacuum Service: operating under a negative gauge pressure or below 

atmospheric pressure. 

3.47 Valve: a 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. 

3.48 Visible Emissions: from well vents, visible emissions are any visible plume 

including water vapor. When the ambient air temperature is 60oF or less a well 

vent shall be considered to have visible emissions if there is any visible plume and 

there is a leak as defined above. 

3.49 Volatile Organic Compound (VOC): as defined in Rule 1020 (Definitions). 

3.50 VOC Collection and Control System: an APCO-approved system that is not open 

to the atmosphere and that is composed of hard-piping, ductwork connections and, 

if necessary, flow inducing devices that transport gas or vapor from a piece or 

pieces of equipment to an APCO-approved control device that has a VOC 

destruction or removal efficiency of at least 99%, or that transports gases or 

vapors back to a process system. 

3.51 VOC Emissions: emissions resulting from the operation of a steam-enhanced 

crude oil production well. Such emissions include uncondensed casing vent 

emissions and any emissions resulting from the handling, transfer, storage, or 

disposal of condensed and uncondensed casing vapors. 

3.52 Well Stimulation: cyclic steam injection of a well for up to 180 days prior to the 

well being placed in service as a continuous steam injection well. 

3.53 Well Vent: an opening on a well head that facilitates or blocks the flow of well 

casing vapors to the atmosphere or to a VOC collection and control system. 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

4.0 Exemptions 

4.1 Any steam-enhanced crude oil production well undergoing service or repair during 

the time the well is not producing. 

4.2 Effective until December 31, 2008, the requirements of this rule for cyclic wells 

shall not apply to the first 100 cyclic wells of a small producer. 

4.2 3 The requirements of this rule for cyclic wells shall not apply to up to 40 wells 

owned by a company and undergoing pilot testing provided; 

4.2.1 4.3.1 the production zone on that property has not been injected with 

steam during the preceding two (2) years, 

4.2.2 4.3.2 the well is located more than 1000 feet from an existing well vent 

vapor collection and control system operated by the company, and 

4.2.3 4.3.3 the operation is under District permit. 

4.3 4 The requirements of this rule shall not apply to up to 40 cyclic wells owned by a 

company and undergoing well stimulation, provided; 

4.3.1 4.4.1 the well is located more than 1000 feet from an existing well vent 

vapor collection and control system operated by the company, and 

4.3.2 4.4.2 the operation is under District permit. 

4.4 5 Effective until December 31, 2008, the requirements of this rule shall not apply to 

up to 20 cyclic wells owned by a company in each stationary source as defined in 

Rule 2201 (New and Modified Stationary Source Review Rule), provided the 

requirements of Section 4.5.1 and Section 4.5.2 are met. Effective on and after 

January 1, 2009, the The requirements of this rule shall not apply to up to five (5) 

cyclic wells owned by a company that is not a small producer, in each stationary 

source as defined in Rule 2201 (New and Modified Stationary Source Review 

Rule), and up to 20 cyclic wells owned by a small producer, provided the 

requirements of Section 4.4.1 and Section 4.4.2 4.5.1 and Section 4.5.2 are met. 

4.4.1 4.5.1 the well is located more than 1000 feet from an existing well vent 

vapor control system operated by the company, and 

4.4.2 4.5.2 the operation is under District permit. 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

4.6 Effective until December 31, 2008, the requirements of this rule shall not apply 

to the first ten (10) wells of a small producer that are responding to steam injected 

from an operator other than themselves and where no contractual agreement for 

injected steam exists, and provided the small producer meets the following 

conditions:

4.6.1 A list of wells that are exempted by Section 4.6 shall be submitted to the 

APCO by July 15, 1998.

4.6.2 Source testing of the well vent that is nearest to the steam injection well 

shall be conducted by January 15, 2001 in order to determine its VOC 

mass emission rate. Source testing shall be conducted in accordance with 

Section 6.3.4.

4.5 4.7 The requirements of this rule shall not apply to components serving the 

produced fluid line. 

4.6 4.8 Except for complying with the applicable requirements of Section 6.1, Section 

6.6.6 and Section 7.2, the requirements of this rule shall not apply to 

components described in Section 4.6.1 through Section 4.6.4. 4.8.1 through 

Section 4.8.4. An operator claiming an exemption pursuant to Section 4.6 4.8

shall provide proof of the applicable criteria to the satisfaction of the APCO. 

4.6.1 4.8.1 Pressure relief devices, pumps, and compressors that are enclosed 

and whose emissions are controlled with an operating VOC collection 

and control system as defined in Section 3.0. 

4.6.2 4.8.2 Components buried below ground. 

4.6.3 4.8.3 Components used exclusively in vacuum service. 

4.6.4 4.8.4 One-half inch nominal or less stainless steel tube fittings which 

have been demonstrated to the APCO to be leak-free based on initial 

inspection using the test method specified in Section 6.3.3. 

4.7 9 Effective on and after January 1, 2009, the The requirements of Section 5.4.1

through Section 5.4.7 5.8.1 through Section 5.8.5 of this rule shall not apply to 

components exclusively handling gas/vapor or liquid with a VOC content of ten 

percent by weight or less (≤10 wt.%), as determined by the test methods in 

Section 6.3.4. 6.3.5.
 PROPOSED June 16, 2011 

  Proposed Rule 4401

5.0 Requirements 

Section 5.1 through Section 5.4 shall be effective until December 31, 2008. 

Section 5.5 through Section 5.9 shall be effective on and after January 1, 2009. 

5.1 No person shall operate a steam-enhanced crude oil production well, except cyclic 

wells meeting the requirements of Section 5.4, unless the uncontrolled VOC 

emissions from any well vent are reduced by at least 99 percent by weight, or

5.2 If several steam-enhanced crude oil production well vents are connected to a vapor 

collection and control system, the total uncontrolled VOC emissions shall be 

reduced by at least 99 percent by weight.

5.3 All components of a well vent vapor collection and control system shall be 

maintained in good repair. A total number of leaks is a violation of this rule if it 

exceeds the number of allowable leaks. Vapor collection and control systems 

serving 501 or more wells shall be determined to be in violation of the number of 

allowable leaks if more than one (1) leak is detected for each 20 wells tested with 

a minimum of 50 wells tested.

Table 2 Number of Allowable Leaks

Number of Steam-Enhanced Crude Oil Production Wells 

Connected to a Vapor Collection and Control System

Number of 

Allowable Leaks

Up to and including 25 3

26 to 50 6

 51 to 100 8

101 to 250 10

251 to 500 15

5.3.1 An operator, upon detection of a leak, shall affix a readily visible tag 

bearing the date on which the leak is detected. The tag shall remain in 

place until the leaking component is repaired. Failure to repair a leak 

within fifteen (15) calendar days shall constitute a violation of this rule. 

The APCO may grant a ten (10) calendar day extension provided the 

operator demonstrates that necessary and sufficient actions have and are 

being taken to correct the leak. Failure to repair a leak after a ten (10) 

calendar day extension constitutes a violation of this rule.

5.3.2 For the purpose of Section 5.3, components of the well vent vapor 

collection and control system shall include all piping, valves, fittings, 

pumps, compressors, tanks, etc. used to collect, control, store, or dispose 

of VOC condensate or non-condensable VOCs prior to blending of VOC 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

condensate with crude oil or blending of non-condensable VOCs with 

gases to be used as a fuel.

5.4 No person shall operate a cyclic well located on properties with less than ten (10) 

cyclic wells, owned by a company, unless the uncontrolled VOC emissions from 

any well vent or system of well vents connected to a single vapor collection and 

control device are reduced by at least 50 percent. Properties shall include 

contiguous and adjacent oil production properties owned by or under control of 

the company.

5.15 An operator shall not operate a steam-enhanced crude oil production well unless 

the operator complies with the requirements of either Section 5.1.1 or Section 

5.1.2. 5.5.1 or Section 5.5.2. 

5.1.1 5.5.1 The steam-enhanced crude oil production well vent is closed and 

the front line production equipment downstream of the wells that carry 

produced fluids (crude oil or mixture of crude oil and water) is 

connected to a VOC collection and control system as defined in Section 

3.0. The well vent may be temporarily opened during periods of 

attended service or repair of the well provided such activity is done as 

expeditiously as possible with minimal spillage of material and VOC 

emissions to the atmosphere. 

5.1.2 5.5.2 The steam-enhanced crude oil production well vent is open and the 

well vent is connected to a VOC collection and control system as defined 

in Section 3.0. 

5.2 6 Determination of Compliance with the Leak Standards

5.2.1 5.6.1 An operator shall be in violation of this rule if any District 

inspection demonstrates that one or more of the conditions in Section 5.2.2 

5.6.2 exist at the facility or if any operator inspection conducted pursuant 

to Section 5.4 5.8 demonstrates that one or more of the conditions in 

Section 5.2.2 5.6.2 exist at the facility. 

5.2.2 5.6.2 Leak Standards 

The following conditions shall be used for determination of violation 

during an inspection pursuant to the provisions of Section 5.2.1. 5.6.1:

5.2.2.1 5.6.2.1 Existence of an open-ended line or a valve located

at the end of the line that is not sealed with a blind flange, plug, 

cap, or a second closed valve that is not closed at all times, 

except during attended operations requiring process fluid flow 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

through the open-ended lines. Attended operations include 

draining or degassing operations, connection of temporary 

process equipment, sampling of process streams, emergency 

venting, and other normal operational needs, provided such 

operations are done as expeditiously as possible and with 

minimal spillage of material and VOC emissions to the 

atmosphere. 

5.2.2.2 5.6.2.2 Existence of a component with a major liquid leak 

as defined in Section 3.0. 

5.2.2.3 5.6.2.3 Existence of a component with a gas leak greater 

than 50,000 ppmv. 

5.2.2.4 5.6.2.4 Existence of a component leak described in Section

5.2.2.4.1 through Section 5.2.2.4.3 5.6.2.4.1 through Section 

5.6.2.4.3 in excess of the allowable number of leaks specified in 

Table 2. 3.

5.2.2.4.1 5.6.2.4.1 A minor liquid leak, or 

5.2.2.4.2 5.6.2.4.2 A minor gas leak, or 

5.2.2.4.3 5.6.2.4.3 A gas leak greater than 10,000 ppmv up to 

50,000 ppmv. 

Table 2 3 Number of Allowable Leaks 

Number of Steam-Enhanced Crude Oil 

Production Wells Connected to a VOC 

Collection and Control System 

Number of Allowable Leaks 

1 to 25 3 

26 to 50 6 

51 to 100 8 

101 to 250 10 

251 to 500 15 

More than 500 

One (1) for each 20 wells 

tested with a minimum of 50 

wells tested. 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

5.3 7 An operator shall comply with the following operating requirements: 

5.3.1 5.7.1 An operator shall not use any component with a leak as defined in 

Section 3.0, or that is found to be in violation of the provisions of Section 

5.2.2 5.6.2. However, components that were found leaking may be used 

provided such leaking components have been identified with a tag for 

repair, are repaired, or awaiting re-inspection after being repaired within 

the applicable time frame specified in Section 5.5 5.9 of this rule. 

5.3.2 5.7.2 Each hatch shall be closed at all times except during sampling or 

adding of process material through the hatch, or during attended repair, 

replacement, or maintenance operations, provided such activities are 

done as expeditiously as possible with minimal spillage of material and 

VOC emissions to the atmosphere. 

5.3.3 5.7.3 An operator shall comply with the requirements of Section 6.7 if 

there is any change in the description of major components or critical 

components. 

5.4 5.8 Inspection and Re-inspection Requirements 

Unless otherwise specified, an operator shall perform all component inspections 

and gas leak measurements pursuant to the requirements of Section 6.3.3. 

5.4.1 5.8.1 Except for pipes and unsafe-to-monitor components, an operator 

shall inspect all other components pursuant to the requirements of Section 

6.3.3 at least once every year. 

5.4.2 5.8.2 An operator shall visually inspect all pipes at least once every year. 

 Any visual inspection of pipes that indicates a leak that cannot be 

immediately repaired to meet the leak standards of this rule shall be 

inspected within 24 hours after detecting the leak. If a leak is found, the 

leak shall be repaired as soon as practicable but not later than the time 

frame specified in Table 3 4 of this rule. 

5.4.3 5.8.3 In addition to the inspections required by Section 5.4.1 5.8.1, an 

operator shall inspect for leaks all accessible operating pumps, 

compressors, and PRDs in service as follows: 

5.4.3.1 5.8.3.1 An operator shall audio-visually (by hearing and 

by sight) inspect for leaks all accessible operating pumps, 

compressors, and PRDs in service at least once each calendar 

week. 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

5.4.3.2 5.8.3.2 Any audio-visual inspection of an accessible 

operating pump, compressor, and PRD performed by an

operator that indicates a leak that cannot be immediately 

repaired to meet the leak standards of this rule shall be 

inspected not later than 24 hours after conducting the audiovisual inspection. If a leak is found, the leak shall be repaired 

as soon as practicable but not later than the time frame specified 

in Table 3 4 of this rule. 

5.4.4 5.8.4 In addition to the inspections required by Section 5.4.1 5.8.1, 

Section 5.4.2 5.8.2 and Section 5.4.3 5.8.3, an operator shall perform the 

following inspections: 

5.4.4.1 5.8.4.1 An operator shall initially inspect a PRD that 

releases to the atmosphere as soon as practicable but not later than 

24 hours after the discovery of the release. An operator shall reinspect the PRD not earlier than 24 hours after the initial inspection 

but not later than 15 calendar days after the initial inspection. 

5.4.4.2 5.8.4.2 An operator shall inspect all new, replaced, or 

repaired fittings, flanges, and threaded connections within 72 hours 

of placing the component in service. 

5.4.4.3 5.8.4.3 Except for PRDs subject to the requirements of 

Section 5.4.4.1, 5.8.4.1, an operator shall inspect a component 

that has been repaired or replaced not later than 15 calendar days 

after the component was repaired or replaced. 

5.4.7 5.8.5 An operator shall inspect all unsafe-to-monitor components during 

each turnaround. 

5.4.8 5.8.6 A District inspection in no way fulfills any of the mandatory 

inspection requirements that are placed upon operators and cannot be used 

or counted as an inspection required of an operator. 

5.5 5.9 Leak Repair Requirements 

5.5.1 5.9.1 An operator shall affix a readily visible weatherproof tag to a 

leaking component upon detection of the leak. An operator shall include 

the following information on the tag: 

5.5.1.1 5.9.1.1 The date and time of leak detection. 

5.5.1.2 5.9.1.2 The date and time of leak measurement. 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

5.5.1.3 5.9.1.3 For a gaseous leak, the leak concentration in 

ppmv. 

5.5.1.4 5.9.1.4 For a liquid leak, whether it is a major liquid leak 

or a minor liquid leak. 

5.5.1.5 5.9.1.5 Whether the component is an essential component, 

an unsafe-to-monitor component, or a critical component. 

5.5.2 5.9.2 An operator shall keep the tag affixed to the component until an 

operator has met all of the following conditions: 

5.5.2.1 5.9.2.1 Repaired or replaced the leaking component, and 

5.5.2.2 5.9.2.2 Re-inspected the component using the test method 

in Section 6.3.3, and 

5.5.2.3 5.9.2.3 The component is found to be in compliance with 

the requirements of this rule. 

5.5.3 5.9.3 An operator shall minimize a component leak in order to stop or 

reduce leakage to the atmosphere immediately to the extent possible, but 

not later than one (1) hour after detection of the leak. 

5.5.4 5.9.4 Except for leaking critical components or leaking essential 

components subject to the requirements of Section 5.5.7 5.9.7, if an 

operator has minimized a leak but the leak still exceeds the applicable leak 

limits as defined in Section 3.0, an operator shall comply with at least one 

of the requirements of Section 5.5.4.1, Section 5.5.4.2, or Section 5.5.4.3

5.9.4.1, Section 5.9.4.2, or Section 5.9.4.3 as soon as practicable but not 

later than the time period specified in Table 3. 4. 

5.5.4.1 5.9.4.1 Repair or replace the leaking component; or 

5.5.4.2 5.9.4.2 Vent the leaking component to a VOC collection 

and control system as defined in Section 3.0, or 

5.5.4.3 5.9.4.3 Remove the leaking component from operation. 
 PROPOSED June 16, 2011 

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Type of Leak Repair Period in Calendar Days 

Gas Leaks 

Minor Gas Leak 14 

Major Gas Leak less than or equal 

to 50,000 ppmv 

5 

Gas Leak greater than 50,000 ppmv 2 

Liquid Leaks 

Minor Liquid Leak 3 

Major Liquid Leak 2 

5.5.5 5.9.5 The leak rate measured after leak minimization has been performed 

shall be the leak rate used to determine the applicable repair period 

specified in Table 3. 4.

5.5.6 5.9.6 The time of the initial leak detection shall be the start of the repair 

period specified in Table 3. 4.

5.5.7 5.9.7 If the leaking component is an essential component or a critical 

component that cannot be immediately shut down for repairs, and if the 

leak has been minimized but the leak still exceeds the applicable leak 

standard of this rule, the operator shall repair or replace the essential 

component or critical component to eliminate the leak during the next 

process unit turnaround, but in no case later than one year from the date of 

the original leak detection, whichever comes earlier. 

6.0 Administrative Requirements 

6.1 Recordkeeping and Submissions 

An operator shall maintain the records required by Section 6.1 and Section 6.2 for 

a period of five (5) years. These records shall be made available to the APCO, 

California Air Resources Board (ARB), and EPA upon request. 

6.1.1 The operator of any steam-enhanced crude oil production well shall 

maintain records of the date and well identification where steam injection 

or well stimulation occurs. 

6.1.2 Effective January 15, 1998, aA small producer shall maintain monthly 

records of county-specific crude oil production. For the purpose of this 

rule, the monthly crude oil production records required by the California 
 PROPOSED June 16, 2011 

  
 Proposed Rule 4401

Division of Oil, Gas, and Geothermal Resources may be used to satisfy 

Section 6.1.2. 

6.1.3 An operator of any steam-enhanced crude oil production well shall keep 

source test records which demonstrate compliance with the control 

efficiency requirements of the VOC collection and control system as 

defined in Section 3.0. 

6.1.4 Effective until December 31, 2008, the results of source tests conducted 

pursuant to Section 4.6.2 shall be submitted to the APCO within 60 days 

after the completion of the source test.

6.1.4 6.1.5 Effective on and after January 1, 2009, the The inspection log 

maintained pursuant to Section 6.4. 

6.1.5 6.1.6 Effective on and after January 1, 2009, r Records of each 

calibration of the portable hydrocarbon detection instrument utilized for 

inspecting components, including a copy of current calibration gas 

certification from the vendor of said calibration gas cylinder, the date of 

calibration, concentration of calibration gas, instrument reading of 

calibration gas before adjustment, instrument reading of calibration gas 

after adjustment, calibration gas expiration date, and calibration gas 

cylinder pressure at the time of calibration. 

6.1.6 6.1.7 Effective on and after January 1, 2009, an An operator shall 

maintain copies at the facility of the training records of the training 

program operated pursuant to Section 6.5. 

6.1.7 6.1.8 Effective on and after January 1, 2009, an An operator shall keep 

a copy of the APCO-approved Operator Management Plan at the facility. 

6.1.8 6.1.9 An operator shall keep submit to the APCO not later than June 

14, 2007 a list of all gauge tanks, as defined in Section 3.0 3.17. The 

list shall contain the size, identification number, the location of each 

gauge tank and specify whether the gauge tank is upstream of all front 

line production equipment. 

6.1.9 6.1.10 The results of gauge tank TVP testing conducted pursuant to 

Section 6.2.3 6.2.5 shall be submitted to the APCO within 60 days after

the completion of the testing. 

6.1.10 6.1.11 Effective on and after January 1, 2007, an An operator that 

discovers that a PRD has released shall record the date that the release 

was discovered, and the identity and location of the PRD that released. 
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   Proposed Rule 4401

An operator shall submit such information recorded during the calendar 

year of the release to the APCO no later than 60 days after the end of the 

calendar year. 

6.2 Compliance Source Testing 

6.2.1 An operator shall source test annually all VOCvapor collection and control 

systems used to control emissions from steam-enhanced crude oil 

production well vents to determine the control efficiency of the device(s) 

used for destruction or removal of VOC. Compliance testing shall be 

performed annually by source testers certified by ARB. Testing shall be 

performed during June, July, August, or September of each year if the 

system's control efficiency is dependent upon ambient air temperature. A 

process system is not subject to compliance source testing requirements. 

6.2.2 If approved by EPA, ARB, and the APCO, an operator need not comply 

with the annual testing requirement of a VOC collection and control 

system is not subject to Section 6.2.1 if all uncondensed VOC emissions 

collected by a vapor collection and control the system are controlled by a 

device meeting one of the requirements in Sections 6.2.2.1 through 

6.2.2.3. incinerated in fuel burning equipment, an internal combustion 

engine or in a smokeless flare. 

 

6.2.2.1 An internal combustion engine subject to District Rule 4702 

(Internal Combustion Engines – Phase 2); or 

6.2.2.2 A combustion device subject to District Rule 4320 (Advanced 

Emission Reduction Options for Boilers, Steam Generators, 

and Process Heaters Greater than 5.0 MMBtu/hr); District Rule 

4307 (Boilers, Steam Generators, and Process Heaters – 2 

MMBtu/hr to 5 MMBtu/hr); or District Rule 4308 (Boilers, 

Steam Generators, and Process Heaters – 0.075 MMBtu/hr to 

2.0 MMBtu/hr); or 

6.2.2.3 A unit subject to District Rule 4311 (Flares). 

6.2.3 If approved by EPA, ARB, and the APCO, an operator need not comply 

with the annual testing requirement of Section 6.2.1 for a vapor control 

system which does not have a VOC destruction device.

6.2.4 An operator seeking approval pursuant to Section 6.2.2 or Section 6.2.3 

shall submit a written request and supporting information to the APCO. 

The District shall evaluate the request and if approved by the APCO, the 

District shall provide EPA and ARB with a copy of the evaluation and 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

shall request EPA and ARB approval. The District evaluation and the 

APCO request shall be deemed approved unless EPA or ARB objects to 

such approval in writing within 45 days of the receipt of the APCO 

request. 

6.2.3 6.2.5 An operator shall comply with the following requirements for 

each gauge tank, as defined in Section 3.0: 3.17:

6.2.3.1 6.2.5.1 Conduct an initial TVP testing of the produced 

fluid in each gauge tank not later than June 14, 2007. 

Thereafter, an An operator shall conduct periodic TVP testing 

of each gauge tank at least once every 24 months during 

summer (July – September), and whenever there is a change in 

the source or type of produced fluid in the gauge tank. 

6.2.3.2 6.2.5.2 The TVP testing shall be conducted at the actual 

storage temperature of the produced fluid in the gauge tank 

using the applicable TVP test method specified in Section 6.4 of 

Rule 4623 (Storage of Organic Liquids). The operator shall 

submit the TVP testing results to the APCO as specified in 

Section 6.1.9. 6.1.10.

6.3 Test Methods 

Test methods that are equivalent to those test methods specified in Section 6.3.1 

through Section 6.3.4 Section 6.3.5 may be used provided that such equivalent 

test methods have been previously approved, in writing, by the EPA, ARB, and 

the APCO. 

6.3.1 The control efficiency of any VOC control device, measured and 

calculated as carbon, shall be determined by EPA Method 25, except 

when the outlet concentration must be below 50 ppm in order to meet the 

standard, in which case EPA Method 25a may be used. EPA Method 18 

may be used in lieu of EPA Method 25 or EPA Method 25a provided the 

identity and approximate concentrations of the analytes/compounds in the 

sample gas stream are known before analysis with the gas chromatograph 

and the gas chromatograph is calibrated for each of those known 

analyte/compound to ensure that the VOC concentrations are neither 

under- or over-reported. 

6.3.2 VOC content shall be analyzed by using the latest revision of ASTM 

Method E168, E169, or E260 as applicable. Analysis of halogenated 

exempt compounds shall be performed by using ARB Method 432. 
 PROPOSED June 16, 2011 

  Proposed Rule 4401

6.3.3 Leak inspection, other than audio-visual, and measurements of gaseous 

leak concentrations shall be conducted according to EPA Method 21 using 

an appropriate portable hydrocarbon detection instrument calibrated with 

methane. The instrument shall be calibrated in accordance with the 

procedures specified in EPA Method 21 or the manufacturer’s instruction, 

as appropriate, not more than 30 days prior to its use. The operator shall 

record the calibration date of the instrument. Where safety is a concern, 

such as measuring leaks from compressor seals or pump seals when the 

shaft is rotating, a person shall measure leaks by placing the instrument 

probe inlet at a distance of one (1) centimeter or less from the surface of 

the component interface. 

6.3.4 Effective until December 31, 2008, for the purpose of Section 4.6.2, the 

VOC mass emission rate shall be determined according to the procedures 

described in the document USEPA-909/9-81-003, September 1981, 

entitled “Assessment of VOC Emissions from Well Vents Associated with 

Thermally Enhanced Oil Recovery”. 

6.3.4 6.3.5 The VOC content by weight percent (wt.%) shall be determined 

using American Society of Testing and Materials (ASTM) D1945 for gases 

and South Coast Air Quality Management District (SCAQMD) Method 

304-91 or the latest revision of ASTM Method E168, E169 or E260 for 

liquids. 

6.4 Inspection Log 

Effective on and after January 1, 2009, an An operator shall maintain an 

inspection log in which an operator records, at a minimum, all of the following 

information for each inspection performed: 

6.4.1 The total number of components inspected, and the total number and 

percentage of leaking components found by component type. 

6.4.2 The location, type, and name or description of each leaking component 

and description of any unit where the leaking component is found. 

6.4.3 The date of leak detection and the method of leak detection. 

6.4.4 For gaseous leaks, the leak concentration in ppmv, and for liquid leaks 

record whether the leak is a major liquid leak or a minor liquid leak. 

6.4.5 The date of repair, replacement, or removal from operation of leaking 

components. 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

6.4.6 The identify and location of essential components and critical components 

found leaking that cannot be repaired until the next process unit turnaround 

or not later than one year after leak detection, whichever comes earlier. 

6.4.7 The methods used to minimize the leak from essential components and 

critical components found leaking that cannot be repaired until the next 

process unit turnaround or not later than one year after leak detection, 

whichever comes earlier. 

6.4.8 The date of re-inspection and the leak concentration in ppmv after the 

component is repaired or is replaced. 

6.4.9 The inspector’s name, business mailing address, and business telephone 

number. 

6.4.10 The date and signature of the facility operator responsible for the 

inspection and repair program certifying the accuracy of the information 

recorded in the log. 

6.5 Employee Training Program 

Effective on and after January 1, 2009, an An operator shall establish and 

implement an employee training program for inspecting and repairing components 

and recordkeeping procedures, as necessary. 

6.6 Operator Management Plan 

By June 30, 2008, an operator whose existing wells are subject to this rule or 

whose existing wells are exempt pursuant to Section 4.0 of this rule on or before 

December 14, 2006 shall prepare and submit an Operator Management Plan for 

approval by the APCO. An operator may use diagrams, charts, spreadsheets, or 

other methods approved by the APCO to describe the information required by 

Section 6.6.4 through Section 6.6.7 below. The Operator Management Plan shall 

include, at a minimum, all of the following information: 

6.6.1 A description of all wells and all associated VOC collection and control 

systems subject to this rule, and all wells and all associated VOC collection 

and control systems that are exempt pursuant to Section 4.0 of this rule. 

6.6.2 Identification and description of any known hazard that might affect the 

safety of an inspector. 

6.6.3 Except for pipes, the number of components that are subject to this rule by 

component type. 
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   Proposed Rule 4401

6.6.4 Except for pipes, the number and types of major components, inaccessible 

components, unsafe-to-monitor components, critical components, and 

essential components that are subject to this rule and the reason(s) for such 

designation. 

6.6.5 Except for pipes, the location of components subject to the rule 

(components may be grouped together functionally by process unit or 

facility description). 

6.6.6 Except for pipes, components exempt pursuant to Section 4.6 4.8 (except 

for components buried below ground) may be described in the Operator 

Management Plan by grouping them functionally by process unit or 

facility description. The results of any laboratory testing or other 

pertinent information to demonstrate compliance with the applicable 

exemption criteria for components for which an exemption is being 

claimed pursuant to Sections 4.6 4.8 shall be submitted with the 

Operator Management Plan. 

6.6.7 A detailed schedule of an operator’s inspections of components to be 

conducted as required by this rule and whether the operator inspections of 

components required by this rule will be performed by a qualified 

contractor or by an in-house team. 

6.6.8 A description of the training standards for personnel that inspect and repair 

components. 

6.6.9 A description of the leak detection training for conducting the test method 

specified in Section 6.3.3 for new operators, and for experienced 

operators, as necessary. 

6.7 By January 30 of each year after 2008, an operator shall submit to the APCO for 

approval, in writing, an annual report indicating any changes to an existing 

Operator Management Plan. 

6.8 The APCO shall provide written notice to the operator of the approval or 

incompleteness of a new or revised Operator Management Plan within 60 days of 

receiving such Operator Management Plan. If the APCO fails to respond in 

writing within 60 days after the date of receiving the Operator Management Plan, 

it shall be deemed approved. No provision of the Operator Management Plan, 

approved or not, shall conflict with or take precedence over any provision of this 

rule. 
 PROPOSED June 16, 2011 

   Proposed Rule 4401

7.0 Compliance Schedule 

7.1 The operator of any new steam-enhanced crude oil production well, or any nonsteam-enhanced crude oil production well converted to a steam-enhanced crude oil 

production well, which commences steam-enhancement operations on or after 

April 11, 1991, shall comply with the requirements of this rule and the applicable 

permit requirements of Rule 2201 (New and Modified Stationary Source Review 

Rule) before steam injection and no later than the first detectable flow at the 

casing vent. 

7.2 Steam-enhanced crude oil production wells and components that are exempt 

pursuant to Section 4.2, 4.3, 4.4, 4.6, or 4.7 4.3, 4.4, 4.5, 4.8 or 4.9 that 

become subject to this rule through loss of exemption status shall not be 

operated until such time that they are in full compliance with the requirements 

of this rule. 

7.3 Effective on and after January 1, 2009, an operator shall be in full compliance 

with the requirements of this rule, unless otherwise specified in the provisions of 

this rule. 
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