SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX C: RACT Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4401 

 

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APPENDIX C 

Reasonably Available Control Technology 

(RACT) Analysis 

June 16, 2011 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

APPENDIX C: RACT Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4401 

 

C - 2

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SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

APPENDIX C: RACT Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4401 

 

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I. REQUIREMENTS OF ANALYSIS 

The Clean Air Act (CAA) Section 182(b)(2) states that ozone attainment plans shall 

assure that RACT for volatile organic compounds (VOC) is applied at certain sources. 

A RACT analysis requires an examination of a rule against Federal rules, regulations, 

and technology guidelines as well as comparing it against rules from other Districts in 

California. District Rule 4401 was compared to federal and state regulations and 

guidance. The following is a discussion of that analysis. 

II. ANALYSIS 

EPA – Control Technique Guidelines (CTG) 

There is no CTG for this source category. 

EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 

Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP or MACT for this source category. 

How does District Rule 4401 compare to rules in other air districts? 

District staff compared control requirements, and work practice standards in District 

Rule 4401 to comparable requirements in rules from the following California 

nonattainment areas: 

• South Coast AQMD Rule 1148, as amended November 5, 1982. 

• Bay Area AQMD, Sacramento Metropolitan AQMD, and Ventura County APCD do not 

have a prohibitory rule that covers the same emission source category. 

South Coast AQMD Rule 1148 

South Coast AQMD Rule 1148 (Thermally Enhanced Oil Recovery Wells) requires that 

ROG emissions from a steam drive well not to exceed 4.5 lb/day or if steamed drive 

wells are connected to vapor control system ROG emissions from the control system 

shall average no more than 4.5 lb/day/connected well. Using CARB emissions factor 

for uncontrolled steam drive well of 220 lb-VOC/day, Rule 4401’s 99% control 

requirement equates to 2.2 lb/day/well, which is more stringent than 4.5 lb/day/well 

(heavy oil production results in no methane or ethane, meaning 100% of ROGs are 

considered VOCs). 

South Coast AQMD Rule 1148 does not specify any fugitive VOC leak detection and 

repair provisions where as Rule 4401 specifies the number of allowable component 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

APPENDIX C: RACT Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4401 

 

C - 4

leaks based on the number of wells connected to a vapor collection and control system. 

Rule 4401 requires an operator, upon detection of a leak, to affix a readily visible tag 

bearing the date on which the leak is detected. Rule 4401 further requires an operator 

to repair a leak within fifteen (15) calendar days; failure to repair the leak would 

constitute a violation of the rule. 

South Coast AQMD Rule 1148 contains a six month exemption for steam drive wells if 

steam is injected more frequently than 45 days and amount of steam injection 

expressed as water is more than 2,000 barrels. Rule 4401 provides exemptions for up 

to 40 cyclic wells owned by a company that are undergoing pilot testing and well 

stimulation. Rule 4401 also exempts for up to 5 cyclic wells (20 cyclic wells for small 

producer) if wells are located more than 1000 feet from an existing well control system 

operated by the company and operation is under District permit. South Coast AQMD 

Rule 1148 does not limit number of wells that can be exempt and Rule 4401 does not 

limit duration of exemption, therefore exemptions in the both rules can not be compared 

directly. 

Both South Coast AQMD Rule 1148 and Rule 4401 require annual testing of vapor 

control systems. However, District Rule waives this testing requirement if uncondensed 

vapors are incinerated in fuel burning equipment, internal combustion engine or in a 

smokeless flare. 

III. RESULTS OF ANALYSIS 

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4401 

satisfies RACT for steam-enhanced crude oil production well vents.