UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

S outh Coast Air Quality Man agement District

Rule 1148.1

Oil and Gas Production Wells

Prepared by: Joanne Wells Reviewed by: Andrew Steckel

August 201 12

RULE IDENTIFICATION

-

Agency: S outh Coast Air Quality Management District ( S C AQMD )

SIP Approved Rule: There are no versions of S CAQ MD Rule 1148.1 which have been SIP approved.

Subject of this TSD: Rule 1148.1

– Oil and Gas Production Wells Adopted

– March 5, 2004

Submitted

– January 10, 2010

RULE SUMMARY

- SCAQMD Rule 1148.1, Oil and Gas Production Wells, is a rule designed to limit volatile organic compound (VOC ) emissions from well

cellars and from sources of untreated process gas locat e d at oil and gas production facilities. This rule will apply to wellheads and well cellars at onshore facilities where petroleum is produced, gathered, separated, processed and

stored. Major provisions of the rule are summarized below:

1. Requirements :
A concentration of a T otal O rganic C arbon (TO C) greater than 500 ppm in

the well cellar is not allowed. Operators are not allowed to open any valve at the wellhead unless a portable container is used to catch and contain organic liquid. Such container must be kept closed to atmosphere when not in use

. Operator shall not allow organic liquid to be stored in well cellar. During equipment maintenance or work on well, operator must remove organic liquid no later than 2 days

, or 8 hours if near a sensitive receptor, after work is complete. Organic liquid can be stored in a portable enclosed storage vessel equipped with air pollution control equipment to reduce the TOC emission to less than 250 ppm at the outlet

. Operator shall pump out the organic liquid in well cellar immediately before

th e well is steamed or after a wellhead is steam cleaned. Operator shall pump out or remove organic liquid accumulated in the well cellar within 5 days or by the close of the following business day if the well

cellar is located within 100 meters of a sensit ive receptor when the TOC concentration is greater than 250 ppm or the depth of the liquid exceeds 2

inches. Operator shall not allow natural gas or produced gas to be vented to the atmosphere. The emissions shall be collected and controlled using a
syste m handling gas for fuel , sale or underground injection or by a device with a VOC vapor removal efficiency of 95% by weight or by demonstrating an outlet VOC concentration of 50 ppm. Operator shall repair any gaseous leaks of 250 ppm TOC or greater

located within 100 meters of a sensitive receptor by close of the following business day or take actions to prevent the release of TOC emissions until repairs have been completed.3 Operators may not r emove or render ineffective a well cellar at an oil and gas prod ucti o n well except for purposes of abandonment or drill new oil and gas production well s unless a well cellar is installed , unless approved in writing by Executive Officer, CARB and USEPA.

2. Inspection Requirements Visually inspect any stuffing box not located in or above a well cellar daily or located in or above a well cellar weekly or any stuffing box near a sensitive receptor daily. Monthly visual inspections of any stuffing box fitted with a stuffing box adapter, a closed crude oil collection contai ner, and a well shut off switch

that will shut down the well when container is full.

Perform quarterly an inspection of all well cellars using EPA Method 21

. After discovery of organic liquid leakage, the operator shall perform inspection of stuffing box and well cellar according to EPA test method 21 or measure the depth of liquid within 2 days, or 8 hours if 100 meters or less of a sensitive receptor

. 3. Exem ptions Oil and gas production wells that have been idle for mo re than 6 months with no liquid leaks or accumulation in well cellar or wells that have been certified as abandoned are exempt from this rule.
Wells or produced gas handling systems undergoing maintenance and repair or drilling or abandonment operations ar e exempt from requirements to remove organic liquids accumulated in well cellar within 5 days and to collect produced gas and to repair leaks near sensitive receptors by close of the business day following the leak discovery as long as the operations are conducted in a manner that minimizes emissions to the atmosphere. Well cellars used in emergencies are exempt from the 500 ppm TOC limit in well cellars, using a port able container to catch and contain organic liquids and the requirement to remove organic accumulated in well cellar within 5 days, as long as cleanup begins with in 24 h ours after each emergency and is completed within 10 calendar days. Oil and gas produc tion wells that produce no more than 1 barrel per day or 200 standard cubic feet per day of produced gas per facility are exempt from the requirement to collect and control gas emissions as long as production wells are not located within 100 meters of a se nsitive receptor.

This rule also includes sections with definition s , recordkeeping requirements and test methods necessary for this rule.

EPA EVALUATION

-

The following criteria were used to evaluate the submitted rule :
1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988) and the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule
Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate complian ce with the CAA § 110(a)(2)(A) requirement for enforceability.4

2. R ACT

– No f ederal g uideline s or CTGs were found that address these specific sources. O ther state and local rules for this category were used to help evaluate the RACT requirements of CAA § 182( b)(2)

. 3. SIP Relaxation

- Where previous versions of rules have been SIP approved, new submittals must comply with CAA § 110(l) and § 193 regarding SIP relaxations.

The requirements in Rule 1148.1 were compared with similar requirements in other local air district rules, such as, Santa Barbara County APCD Rules 325 and
344, and Ventura County APCD Rule 71.4. The requirements in SC AQMD Rule

11 48.1 are more stringent th an the requirements found in the other rules. As a

result we have determined that this rule generally fulfills RACT requirements

. The monitoring, recordkeeping, reporting and other requirements generally ensure that

the submitted rule can be enforced. Last ly, there are no requirements regarding well cellars or wellheads at oil and gas facilities in the SIP, so the submitted rule strengthens the SIP and complies with CAA §110(l) and § 193.

RULE DEFICIENCIES

– We have not identified any deficiencies with Rule 1148.1 sufficient for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

- The following revision is not currently the basis for rule disapproval, but is

recommended for the next time the rule is amended.

1. For clarity and enforcement, we recommend including a definition for the term “organic liquid”.

EPA ACTION

- The submitted Rule 1148.1 will incorporate new provisions for well cellars and wellheads at oil and gas facilities into the SIP , therefore strengthening the SIP

. The VOC emission reductions for this rule were estimated to be 1.76 tons per day. The rule fulfils the relevant CAA §110 and part D requirements. EPA staff recommends approval of Rule 1148.1 pursuant to CAA § 110(k)(3)

.

REFERENCES

– 1. S CA QMD Rule 1148.1

, Oil and Gas Production W ells , as submitted on January 10, 20 1 0.

2. “Final Staff Report For Proposed Rule 1148.1 and Proposed Amended Rule 222”, South Coast Air Quality Management District, February 24,

2004.