Mr. Matt Young
Santa Barbara County
Planning and Development, Energy and Minerals Division
As a resident of Santa Barbara County, I am concerned about ERG's proposed West Cat Canyon Revitalization Plan Project and the impact it will have on our communities, resources, infrastructure, health, safety, and environment. The following should be included in the EIR:
• Map all aquifers within 1 mile of project boundary or underground thermal stimulation activity, if it exceeds project boundary (incl. PUC pipeline to be replaced as well as all pipelines to be used by project outside of the project boundary)
• List ALL chemicals (compounds, gasses, etc.) used at the site, and explain in clear terms what goes into the ground, intentionally or incidentally, aside from water, at every phase of extraction and maintenance processes in the project. If nothing goes into wells except for water, make a declaration of this fact in clear terms.
• Identify all naturally occurring substances that are likely to be disturbed during all phases of the project, what, if any, additional pressurizing properties they are likely to contribute during or after thermal treatments, and their affects on human health if they migrate into surrounding aquifers
• Plan to notify all neighbors within two miles of project boundary of risk of aquifer contamination and provide testing for anything that would indicate a leak or spill,, free of charge for all residential and agricultural wells before drilling, after each phase of injection, flooding, and pumping, until wells are either shut down or transitioned to inactive status, then follow up with biyearly monitoring for five years.
• Plan to monitor all above and below ground water in multiple sites, at or near project boundary and all pipelines for anything that would indicate a leak or spill, before drilling, after each phase of injection, flooding, and pumping, until wells are either shut down or transitioned to inactive status, then follow up with biyearly monitoring for five years.
• Provide evidence to show that all injection techniques used on the project will not affect aquifers. Define area and depth of below-ground disruption caused by drilling, thermal techniques, and pumping and identify all possible routes that contaminants might migrate to aquifers
• Provide evidence that demonstrates that injection disposal of produced water or muds will affect no aquifers.
• Declare all quantities and origins of all water to be used, for what, where, and when.
• Provide map of all “approved disposal sites” for all produced water and muds. Include quantities and content of disposal materials, and time tables.
• Show permeability and porosity of all subsoils within 3000’ of project, as well as geological formations that might fissure during pressurization or in the case of an earthquake.
• Provide full explanation of “beneficial reuse program,” including all environmental and health impacts resulting from processing, transport, and reuse. Include full explanation of all reuse applications.
• Explain how all water to be used for steam extraction will be purified, and and what emissions will be produced in this process.
• Quantify and state total emissions from all phases of project, using metric ton per year value, and the health impact on communities within unsafe dispersal areal, including but not limited to cumulative generator emissions (including the “four historic generators” mentioned in the NOP), truck emissions, flaring emissions, bore hole emissions, processing emissions, emissions related to re-injection and disposal, emissions related to clean-up, etc., and provide break down numbers for analysis.
•Provide map of “wind rose” from the project, where emissions are likely to migrate and in what quantities, define expected impact on environment and human health, and mitigation measures.
• Disclose the composition/components of all emissions, with human toxicity levels.
* Provide warning system for accidental releases of hydrogen sulfide gas or other toxic gasses.
• Disclose all potential tenorm radiation exposure issues
• Study what possible particulate contaminants in existing soil due to previous oil production will be released into the air during construction, grading, road making, drilling, digging activities etc..
• Provide quantities of methane emissions for each phase of the project
• Show how this project’s emissions plan is in accord with state and federal emission reduction plans
• Provide information on how much gas will be flared, what emissions will be released during flaring, and what the health risks are to exposure to these emissions
• Estimate the cumulative methane from old and new wells, monitor actual methane, and report.
• Define “proper disposal of muds” with specific techniques and locations.
*Outline how company and/or permitting agency will guarantee that all truckers dispose of contaminated soil in appropriate manner
• List chemical composition of muds being disposed and explain impacts on soils and biology at site.
• Provide explanation of impact of pipeline construction, refurbishing, and use (including all spills) on soils and biology.
• Provide explanation of impact of platform grading, and well drilling (as well as spills) on soils and biology.
• Study and report on the impact of noise pollution from construction and production on biology at, and within 2 miles of the project perimeter in at least four opposing compass directions.
• Study and report on the impact of all planned “thermally enhanced” activities, including steam generator operation on soils and biology at site.
• Study and report on the impact of produced water disposal and/or re-injection on soils and biology at site.
• Study and report on the project’s impact on all endangered or sensitive species, including migratory species in all studies.
• Study and report on the impact of planned mud and/or produced water reuse or disposal on soils and biology with regard to what impact it might have on human health, future land use, local livestock, and wildlife, including threatened and endangered species.
• Provide detailed risk management plan for oil spill, as well as produced water spill, and chemical spill, above ground, below ground (incl possible migration paths), as well as into aquifers.
• Provide detailed risk management plan for brush fire, chemical fire, gas/oil fire and explosions, including public notification plan
• Provide detailed risk management plan for earthquakes or other natural disasters, including public notification plan
• Provide projected clean-up and restoration costs for likely, possible, and worst case scenario accidents, as a result of events caused by man or by nature.
• Provide proof of financial ability and intention to pay full cost of clean-up, restoration, rehabilitation, and compensation for any accident, release of produced water, oil or any toxic substance including air emissions resulting from the project.
• Report on the condition, including stress test data, of all existing well casing, to be used for injection or extraction, as well as those that are not used but could seep or flood as a result of below ground pressure or activity, and demonstrate suitable durability related to use (ie pressures, temperatures, flooding), and in the case of earthquake. Provide reports on twenty casing failures, in projects utilizing stimulation and extraction techniques similar to those employed in this project, beginning with all ERG and related company projects in closest vicinity to the project, and compiling, as needed, data from other companies in closest vicinity until the number twenty is reached.
• Inspect all exiting pipelines and provide proof that they will not leak. Replace any pipelines that show evidence of corrosion or damage.
• Provide plan for notifying public within five miles of risks during injections, and of injection timetable.
• Study and report on the potential increase in seismic activity of all employed injection techniques including waste injection. Provide data on all seismic activity caused by waste injection, or ANY “thermally enhanced production” in the county, in California, and in the United States, with analysis of all common factors.
• Provide seismic monitoring in at least two locations on the site, with one being closest to the greatest amount of injection activity, and up to 3,000’ outside the project polygon in four opposing directions before development of the site, at the onset of activity, during all activity, and for one year after completion of activity, including drilling, steaming, extraction, and disposal.
• Provide map of fault lines within 10 mile vicinity of project.
• Provide a list of ALL chemicals (compounds, gasses, etc.) used at the site, whether introduced or naturally occurring but disturbed by extraction activities, and all possible health affects of exposure by spill, water contamination (above and below ground), emissions, soil contamination, contaminated rain or rain run-off, particulates settling on agricultural products, and ingesting livestock that have suffered any of the above exposures. Include risk to on-site employees, site visitors, people living and working in the vicinity, and livestock.
• Study and report on the health impacts, and community impacts of increased truck traffic
* Provide a plan for emergency first aid for residents and workers who breathe in H2S from accidental releases.
• Quantify how much total gas will be stored in tanks and pipes at any given time during the project, and map of where gas will be stored.
• Map all facilities
• Provide explanation of the use of the new pipeline, what quantity of gas will travel through it, when, and in which direction.
• Show map of all new well pads to be graded.
• Explain storage locations of all project materials including gas, pre-use water, produced water, muds, and chemicals, construction materials, repair materials, and maintenance materials, in what quantities, on and off property, and map the route of their migration to and from these sites. Provide evaluation of health and safety risk from these materials.
• Provide a full explanation of all production facility expansions and timelines.
• Provide a map of the depth and area of influence of all proposed production activity, as well as existing and historic wells, oil or groundwater reservoirs, or historic waste disposal wells.
• Provide separate maps of gas and oil facilities
* Evaluate local property values. Assess how expansion of oil operations will impact property value. Provide proof of financial ability and intention to compensate homeowners for lost property value, as well as comprehensive and fair plan for doing so.
• Map of all truck traffic, including transport of chemicals, petroleum products, pre-use water, produced water, muds, and gas, as well as projected truck volumes per day at all phases of project.
• Provide traffic study for all truck traffic and evaluate impacts on communities, and estimate of road damage.
• Study the incidence of trucks leaking materials, toxic or non-toxic, solid or liquid, in quantities that may not be large enough to qualify as a “spill” but that can be considered road hazards, health risks, nuisances or eyesores on public roads, or on local private roads and driveways. Provide a plan for response and clean-up that includes receipt of complaints, notifications, speedy response, clean-up, and compensation if applicable.