TECHNICAL MEMORANDUM

Transcription

1 NEWTON GEO-HYDROLOGY CONSULTING SERVICES P.O. BOX 0 SANTA BARBARA, CALIFORNIA 0 TECHNICAL MEMORANDUM TO: FROM: Citizens For Responsible Oil And Gas (CFROG) Brad Newton, Ph.D., P.G RE: Summary Review of Submittals to LARWQCB INVESTIGATIVE ORDER NO. R AND R-0-0 DATE: October, 0 EXECUTIVE SUMMARY On December, 0, the Los Angeles Regional Water Quality Control Board issued Investigative Orders to provide a technical or monitoring report on the disposal of well drilling fluids, well completion fluids, and production fluids to land for all known Oil and Gas operations in Los Angeles and Ventura County, California, in order to evaluate the potential impacts or threatened impacts to water quality posed by the discharge. These discharges may pose a significant threat to water quality, especially considering the magnitude and areal extent of oil production activities in the Los Angeles Region and the Region s reliance on groundwater as a source of drinking water. The Los Angeles Regional Water Quality Control Board issued Investigative Order No. R to Ojai Oil Company Oil and Gas operations in Los Angeles and Ventura County, California, and Investigative Order R-0-0 to Anterra Energy Services in Ventura County. Ojai Oil Company discharged exploration and or production fluids to a sump. The presence of toluene and high concentrations of inorganic compounds in exceedance of the MCL for drinking water are present in adjacent water wells. Based on these findings there is cause for concern that oil and gas exploration and production activities have contaminated groundwater aquifers within the County of Ventura. Further investigation would be necessary to understand the extent of groundwater contamination/impacts from oil and gas operations throughout the county. INTRODUCTION Dr. Brad Newton and a few members of the CFROG Board of Directors meet on September, 0 to request that Dr. Newton summarize the responses from two oil and gas operators in the County of Ventura to recent Investigative Orders issued by the Los Angeles Regional Water Quality Control Board (Regional Board). The Investigative Orders state: The purpose of this Order is to obtain information regarding the management of the discharges of wastes to land during drilling and completion of oil and gas wells and the P.O. Box 0, Santa Barbara, CA 0 Telephone (0) - bnewton@nghcorp.com

2 DATE: October, 0 Page of discharge of fluids associated with oil and gas production and to assess the threat of water quality from such discharges. The Regional Board needs the required information to characterize the volume and type of fluids discharged to land and to evaluate the potential impacts or threatened impacts to water quality posed by the discharge. These discharges may pose a significant threat to water quality, especially considering the magnitude and areal extent of oil production activities in the Los Angeles Region and the Region s reliance on groundwater as a source of drinking water. Members of the CFROG Board provided Dr. Newton with documents submitted by the two oil and gas operators: Ojai Oil Company and Anterra Energy Services. Additionally, Dr. Newton obtained information on this matter directly from the Regional Board website addressing Oil and Gas Operation - Sumps and Storage ( /programs/oil_and_gas/sumps_and_storage/). This summary review is based on the information provided by CFROG and the Regional Board. Dr. Newton s conclusions and suggestions assume that the data contained therein is accurate. Dr. Newton in no way warrant the accuracy of this information or its completeness, and therefore advises CFROG or others that any use of these facts, if asserted by CFROG or others, would be subject to proof. BACKGROUND On December, 0, the Los Angeles Regional Water Quality Control Board issued Investigative Order No. R-0-00 to provide a technical or monitoring report on the disposal of well drilling fluids, well completion fluids, and production fluids to land for Ojai Oil Company Oil and Gas operations in Los Angeles and Ventura County, California (see Attached #). Similarly, Anterra Energy Services was issued Investigative Order R-0-0 (see Attachment #). An excerpt from the Order is as follows: The technical report must include the following information, in the form of written descriptions, a spreadsheet, and maps: ) The locations of all current and historic sumps in your area of operations used in the discharge of fluids to land. Provide all information regarding liner material used with each sump, if any. Provide the status of all sumps, including active, inactive, closed with cleanup, closed without cleanup, or unknown. For sumps closed with cleanup, describe the cleanup activities and cleanup level. ) The procedures you use to close or abandon sumps, or otherwise cease their operation. 0 E Carrillo Street, Santa Barbara, CA 0 (0) - bnewton@newtongh.com

3 DATE: October, 0 Page of ) The estimated total annual amount of fluid previously discharged into each historic and active sump, and estimated annual amount of fluid to be discharged to active sumps going forward. ) The physical and chemical composition of any fluids discharged into each sump. ) The physical and chemical composition of any solidified waste in each sump. ) The location of any domestic, municipal, and commercial water wells within a halfmile radius of any current or historic sump. ) Historic water quality data available for any wells within a half-mile radius of any current or historic sump. Attachment A lists the constituents we are most interested in for historical data (as well as current data). ) Current sampling results for any wells within a half-mile radius of any current or historic sump. You are required to sample these wells for the constituents listed in Attachment A and submit the results in your technical report. ) Locations, well construction, and survey data for any monitoring wells in the vicinity of any current or historic sumps, and water quality data associated with these wells. The Regional Board needs the required information to characterize the volume and type of fluids discharged to land and to evaluate the potential impacts or threatened impacts to water quality posed by the discharge. These discharges may pose a significant threat to water quality, especially considering the magnitude and areal extent of oil production activities in the Los Angeles Region and the Region's reliance on groundwater as a source of drinking water. Ojai Oil Company and Anterra Energy Services have responded to the Regional Board s Investigative Order. The following section summarizes water quality data as required by items # and # in the list above. WATER QUALITY FROM NEARBY WELLS The required technical report must include information on historic water quality data available for any wells within a half-mile radius of any current or historic sump, as well as, current sampling results for any wells within a half-mile radius of any current or historic sump. The respondent is required to sample these wells for the constituents listed below (Attachment A of the Investigative Order) and submit the results in the technical report. Attachment A is as follows: Water Quality Analysis Groundwater samples collected from wells and injection zones shall be analyzed by a laboratory certified by the Environmental Laboratory Accreditation Program, using current applicable EPA-approved analytical methods for water for the following: 0 E Carrillo Street, Santa Barbara, CA 0 (0) - bnewton@newtongh.com

4 DATE: October, 0 Page of A. Total dissolved solids B. Metals listed in California Code of Regulations, Title, Section., Subdivision (a)()(a) C. Benzene, toluene, ethylbenzene, and xylenes D. Total petroleum hydrocarbons for crude oil E. Polynuclear aromatic hydrocarbons (including acenaphthene, acenaphthylene, anthracene, benzo[a]anthracene, benzo[b]fluoranthene, benzo[k]fluoranthene, benzo[a]pyrene, benzo[g,h,i]perylene, chrysene, dibenzo[a,h]anthracene, fluoranthene, fluorene, indeno[,,-cd]pyrene, naphthalene, phenanthrene, and pyrene) F. Radionuclides listed under California Code of Regulations, Title, Table G. Methane H. Major and minor cations (including sodium, potassium, magnesium, and calcium) I. Major and minor anions (including nitrate, chloride, sulfate, alkalinity, and bromide) J. Trace elements (including lithium, strontium, boron, iron, and manganese) Ojai Oil Company responded (Attachment #) in part to the Investigative Order R-0-00 and the Regional Board has posted the response to their web site. Water quality reports for four water wells sampled near the Ojai Oil Company sump were submitted to the Regional Board following the initial response and are posted on the Regional Board web site for Ojai Oil Company (Attachment #a-d). The four water wells sampled are located within a one-quarter mile distance from the Ojai Oil Company sump. Two of the water wells (Mexican Well and Smith Well) are at lower elevations (down-gradient) and two wells (Topa Lane Well and Sisar Grove Well) are at higher elevations (up-gradient) as compared to the elevation of the sump. The water sample from the Mexican well, nearest and at lower elevation to the sump, analyzed by Fruit Growers Laboratory Inc., contains the organic compound toluene and high concentrations of inorganic compounds in exceedance of the associated MCL for drinking water. The water sample from the Smith well, next nearest well and at lower elevations, contains no organic compounds, but moderate concentrations of inorganic compounds in exceedance of the associated MCL for drinking water. The water sampled from the Topa Lane and Sisar Grove wells, at a higher elevation than the sump, have no organic compounds and only a few inorganic compounds with concentrations in exceedance of the associated MCL for drinking water. Anterra Energy Services responded (Attachment #) in part to the Investigative Order R- 0-0 and the Regional Board has posted the response to their web site. Water quality reports for water wells sampled near the Anterra Energy Services tank farm were included in the submittal to the Regional Board. 0 E Carrillo Street, Santa Barbara, CA 0 (0) - bnewton@newtongh.com

5 DATE: October, 0 Page of 0 The groundwater sampled and presented in the Anterra Energy Services response shows no organic compounds. Inorganic compounds were reported in the groundwater samples and the concentrations of a few constituents are in exceedance of the MCL for drinking water. CONCLUSIONS The Los Angeles Regional Water Quality Control Board issued Investigative Orders to provide a technical or monitoring report on the disposal of well drilling fluids, well completion fluids, and production fluids to land for all known Oil and Gas operations in Los Angeles and Ventura County, California, in order to evaluate the potential impacts or threatened impacts to water quality posed by the discharge. These discharges may pose a significant threat to water quality, especially considering the magnitude and areal extent of oil production activities in the Los Angeles Region and the Region s reliance on groundwater as a source of drinking water. Ojai Oil Company discharged these fluids to a sump and the presence of toluene and high concentrations of inorganic compounds in exceedance of the MCL for drinking water are present in adjacent water wells. Based on these findings there is cause for concern that oil and gas exploration and production activities have contaminated groundwater aquifers within the County of Ventura. Further investigation would be necessary to understand the extent of groundwater contamination/impacts from oil and gas operations throughout the county. 0 E Carrillo Street, Santa Barbara, CA 0 (0) - bnewton@newtongh.com