CALIFORNIA AIR RESOURCES BOARD
South Coast Air Quality Management District
9150 Flair Drive
El Monte, CA
August 11, 1988
88-11-1 Status Report on Update of the Post-87 Motor
88-11-2 Public Meeting to Consider Approval of a 001
Suggested Control Measure for the Control of
Organic Compound Emissions from Sumps used in
Oil Production Operations.
ITEM #88- 11 -2
Suggested Control Measure for the Control of Organic Compound
Emissions From Sumps Used in Oil Production Operations.
We recommend that the Air Resources Board approve the Suggested
Control Measure and direct us to forward it to appropriate air
pollution control and air quality management districts for their
use in developing regulations.
An oil production sump is a surface impoundment or depression in
the ground that is in continuous use for separating crude oil,
water, and solids in oil production operations. Sumps are
classified as primary, secondary, or tertiary.
In areas of California where crude oil is produced, there are
more than 1,400 sumps having a total surface area exceeding
8,700,000 square feet.
Although data necessary to accurately estimate the emissions from
each sump are not available, the data indicate that some sumps
emit significant amounts of organic compounds into the
atmosphere. The available data were used to estimate a
reasonable emissions inventory for sumps. Statewide emissions
from sups are approximately 40 tons per day. Approximately 80
percent of those emissions occur in Kern County, 10 percent occur
in Fresno County, and the remainder occur in oil-producing areas
of the South Coast, South Central Coast, and North Central Coast
Emission control technologies
Evaporative organic compound emissions from sumps can be
controlled by covering the sumps with flexible membrane floating
covers, rigid pontoon floating covers, fixed covers, or by
replacing the sumps with tanks. Each of these approaches to
emission control can be expected to achieve an emission control
efficiency of at least 90 percent by weight.
Suggested Control Measure
The SCM would require that operators retrofit their sumps with
covers, replace them with storage tanks, or any equivalent
method, as long as prior consent from the APCO is obtained.
The Suggested Control Measure contains exemptions from control
requirements for secondary and tertiary sumps that contain low
concentrations of organic compounds, that have low emissions, or
are small and are operated by small oil producers. The SCM is
structured to allow each district to choose the applicability and
extent of the exemptions, considerations peculiar to that
Standard, inexpensive test methods discussed in the Board report
can be used to document that the sumps are exempt because of low
VOC concentration. Alternatively, a more expensive test method
can be used to directly determine sump emissions if
owner/operator of a sump feels that the VOC concentration does
not accurately reflect the potential of the sump to emit.
The exemption for small sumps would provide relief to small oil
producers operating small, non-primary sumps. Emissions from
those sumps should be only a small fraction of the total sump
emissions in California.
Cost of Controls
The cost of controlling sump emissions varies over a wide range,
depending on the sump type and emissions, the size of the sump,
and the control technology applied. On average, the cost-effectiveness
ratio for primary sumps, which are the most emissive sumps, would be less
than $1.00 per pound of NMOC emissions reduced. The cost-effectiveness
for tertiary sumps, many of which have very low emissions, would be
approximately $1.00 to $50.00 per pound of NMOC emissions reduced.
Reductions of NMOC emissions from sumps are expected to be from
25 to 75 percent or an amount ranging from 10 to 30 tons per day
statewide, depending on the stringency of rules adopted by the
No adverse environmental impacts from the application of any of
the control strategies discussed in this report have been
identified with respect to earth, water, air, plant and animal
life, noise level, light and glare, use of land and natural
resources, or sociological factors.