UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

South Coast Air Quality Management District 

Rule 1148.1

Oil and Gas Production Wells

Prepared by: Joanne Wells

Reviewed by: Andrew Steckel

August 2011
2

RULE IDENTIFICATION -

Agency: South Coast Air Quality Management District

(SCAQMD)

SIP Approved Rule: There are no versions of SCAQMD 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 located 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 Total Organic Carbon (TOC) 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 

the 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 sensitive 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 

system 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 remove or render ineffective a well cellar at an oil and 

gas production well except for purposes of abandonment or drill new oil 

and gas production wells 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 container, 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. Exemptions 

Oil and gas production wells that have been idle for more 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 are 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 portable 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 within 24 hours after each 

emergency and is completed within 10 calendar days. 

Oil and gas production 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 sensitive receptor.

This rule also includes sections with definitions, 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 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 
4

2. RACT – No federal guidelines or CTGs were found that address these

specific sources. Other 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 SCAQMD Rule 

1148.1 are more stringent than 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. Lastly, 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. SCAQMD Rule 1148.1, Oil and Gas Production Wells, as submitted on 

January 10, 2010.

2. “Final Staff Report For Proposed Rule 1148.1 and Proposed Amended 

Rule 222”, South Coast Air Quality Management District, February 24, 

2004.