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priate agencies (including the Regional Water Quality Control Board) of detailed plans adequately providing for the elimination of petroleum odors and all potential fresh water or ocean water quality problems. Monitoring programs to record land surface and nearshore ocean floor movements shall be continued in all areas of subsidence problems and shall be initiated in locations of new large-scale fluid extraction on land or nearshore before operations begin. Such monitoring shall continue during and after liquid and gas extraction operations until surface conditions have stabilized. Costs of monitoring and mitigation programs shall be borne by liquid and gas extraction operations, overseen by an appropriate State agency.

84. Recommendations for Increasing Oil Recovery Efficiency. It is recommended that the Legislature (1) enact legislation to require the California Division of Oil and Gas and the State Lands Commission to regulate petroleum completion and production for individual wells, including setting maximum efficient rates of production, as analogous government agencies do in other major. oil-producing states; and (2) adopt a resolution calling for the Federal Energy Administration to encourage primary, secondary, and tertiary production from existing wells.

85. Recommendation for Disclosing Exploration and Production Data. To improve the information base for State energy planning and to encourage exploratory activities, thereby encouraging possible petroleum discovery and production both onshore (where petroleum activities are environmentally preferable) and offshore, it is recommended that the Legislature require all original exploratory and production data from surveys or drilling of wells (including all logs, complete well histories, cores, drilling cutting, water samples, chemical analyses, pressure and temperature measurements, etc., but excluding proprietary interpretive information) on publicly or privately owned California lands to be submitted within 60 days after finishing to the Division of Oil and Gas, with appropriate assurances of strict confidentiality, and to be made public information one year after submittal, except that where such public disclosure would result in severe inequity to a well operator, yearto-year extensions of confidentiality may be granted by the Division of Oil and Gas. The Energy Commission and the State Lands Commission shall be allowed access to all such data on a confidential basis for the purposes of energy resource development planning.

86. Recommendations for Avoiding Adverse Impacts of Federal OCS Petroleum Development. It is recommended that the Governor, the Legislature, the California congressional delegation, and all concerned State agencies seek agreement from the Department of Interior and other Federal authorities that Federal Outer Continental Shelf (OCS) leases will be approved by the Department of Interior only if the following conditions are met: a. Demonstration of Need. Need for Federal OCS development off California shall be clearly determined as required in Policy 81.

b. Develop and Disclose Long-Term Plans. One-, five-, and ten-year plans for petroleum production and all related development as described above in Policy 82, and their impacts on the California coast, shall be fully developed and disclosed. It is recommended that the present leasing system be changed to separate pre-production exploration from the decision to develop and produce on a lease, in order that data about the OCS resource, its value, and the offshore and onshore environmental and planning implications of developing and producing the resource can be accumulated prior to a decision as to whether private companies should be given the right to produce. c. Provide for Public Review. Opportunities for effective review of proposed OCS exploration and development plans shall be provided for the general public, interested units of State, regional, and local government, and other segments of the communities most immediately affected by OCS development activities. d. Prevent Drainage of State Petroleum Sanctuaries. The leases in question shall be sufficiently separated from the State petroleum sanctuaries to prevent drainage of oil and gas reservoirs that may lie partially on State submerged lands. e. Establish Stringent Safety Standards. Petroleum production under Federal jurisdiction off the California coast shall be made subject to safety standards at least as stringent as those for production on State-regulated offshore areas, including those contained in the California Division of Oil and Gas regulations and the manual of procedures of the State Lands Division and standards set forth in Coastal Plan policies. (See especially Policies 11, 83, and 119.)

f. Evaluate Unitization or Consolidation Possibilities. The possibility of unitization or consolidation of all operations and facilities both offshore and onshore shall be fully evaluated and required where feasible, as described in Policy 83(c) for California operations.

g. Consider Use of Subsea Systems. The possibility of use of submerged drilling, completion, and production systems that have been adequately tested to meet rigid environmental safety standards shall be fully evaluated as a partial alternative to platforms and required where technically and economically feasible, except where use of platforms would not cause any significant adverse aesthetic or other environmental impact..

h. Some OCS Revenues Should Go to States. It is recommended that the Federal government provide funds to California and to other coastal states prior to leasing, with the funds to be reimbursed either through a fee related to production volumes, or by making available a portion of its revenues from OCS lease sales or production royalties, or by granting funds from some other source, to assist the State and local governments in (1) planning for and overcoming or mitigating any adverse impact of this production (e.g., planning for transportation terminals, additional refineries, pipelines, sepa

ration, treatment, and storage facilities, and
other support facilities in a way that minimizes
environmental impacts); and (2) purchasing
land for recreation or providing other amenities
along the coast to help offset the impact of
OCS development.

1. Designate Sanctuaries in Certain Areas.
Sites and tracts shall be designated as Federal
petroleum resource sanctuaries (1) if they are
unusually subject to the risk of oil spills due to
geological seismic disturbance; or (2) if they
offer unusual coastal aesthetic assets or the
local economy is particularly dependent upon
the protection of coastal aesthetic assets.
Portions of the Santa Barbara Channel, Mon-
terey Bay, Santa Monica Bay, and San Pedro
Bay would appear to be candidates for sanc-
tuary status.

j. Compatibility with Coastal Plan Policies. Federal OCS development and related activities shall be compatible with all other policies set forth in the Coastal Plan.

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To see that the Geological Survey Regulations and OCS Orders

are fully observed, a comprehensive inspection system has been developed. OCS operators must receive approval before commencing any work.

Operators are required to submit a notice and detailed description of all work they desire to perform. All applications to drill are submitted to the District Engineer, and are thoroughly reviewed and analyzed prior to approval or recommendation for approval to the Supervisor. Simple procedures such as removing, servicing, or replacing a sub-surface valve, modifying a header, flowline, or other piping, also require approval. Each procedure or application is reviewed by a petroleum engineer. If necessary, the program is either discussed with the operator or additional information is requested and reviewed prior to approval. The objective in this requirement for advanced approval is to insure that no operation is conducted without thorough planning for safety, conservation, and protection of the environment, and to determine that all oprations meet the requirements established by the revised regulations and OCS Orders.

Santa Barbara Channel OCS operation inspections are performed by the Santa Barbara District office. Before the January 28, 1969 Platform A spill, one

petroleum engineer and one engineering technician were assigned to the Santa (February 1976) Barbara District. The Santa Babara District staff presently/consists of three

petroleum engineers and eight engineering technicians.

The engineering tech

nicians spend nearly full time in the field. The Assistant District Engineer divides his time between the office and the field and the District

Engineer spends most of his time in the office. The eight engineering technicians spend an average of 300 man-hours per week inspecting operations in the Santa Barbara Channel, where currently there are five OCS platforms and two onshore facilities receiving production from the platforms. At present

two floating drilling vessels operate in the Santa Barbara Channel; except for brief intervals, no more than two floating drilling vessels have operated at the same time. The ratio of Santa Barbara District personnel to the number of Santa Barbara Channel operations has permitted the Geological Survey to scrutinize closely all operations. In addition to this detailed field supervision provided by the Santa Barbara District, the Pacific Area office, the Western Region office, and the Geological Survey headquarters also closely follow and direct the Santa Barbara Channel operations.

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All operations, regardless of the activity, receive regular on-site inspection for compliance with the regulations and OCS Orders. Operations in the Dos Cuadras field (Platform Hillhouse, Lease OCS-P 0240, and Platforms A and B, Lease OCS-P 0241) are inspected daily. The inspector is on the facility for an 8-hour period, randomly observing various operations, testing equipment, and checking for pollution.

The production and

drilling decks are checked at least three times during this inspection period. Conversation with operating and contract personnel has proven to be a worthwhile means of being alerted to potential hazards and the need to replace or modify existing equipment. Platforms Hogan and Houchin, Lease OCS-P 0166 are inspected at least once a week. Critical operations are observed regardless of what time of day or night they occur.

Two onshore processing facilities handle all of the Federal OCS lease fluid and gas production. The production from Lease OCS-P 0166 is processed at the Phillips La Conchita plant and production from Leases OCS-P 0240 and OCS-P 0241 is processed at the Mobil Sea Cliff plant; both plants are near Rincon Point. These two plants are inspected weekly. Also Lease Automatic Custody Transfer (LACT) meter provings are regularly monitored at these two onshore facilities.

If a floating drilling vessel or drilling unit has not been in service for some time or if a drilling unit is new to the area, a

detailed inspection is performed to insure conformance with regulations and OCS Orders, before commencement of drilling operations. These predrilling inspections are comprehensive and often require several days to complete. After a well has been spudded and normal

drilling is in progress, drilling inspections are performed at least weekly. It is not uncommon to make daily drilling inspections at certain wells. Again, all critical phases of drilling operation are observed whatever time during the day or night they may occur. Critical phases include, but are not limited to, casing-cementing operations, casing and blowout equipment pressure tests, line-lap pressure tests, wireline work, drill-stem formation tests, and any other tests or operations not considered to be routine.

When a well is either abandoned or suspended, a Geological Survey inspector witnesses the setting of all required cement plugs, the cutting off of the several casing strings below the sea floor, and the removal of all subsea equipment.

b.

Semi-Annual Inspections and Enforcement Procedures

In addition to the daily and weekly inspections, and

the observation of all critical operations, each onshore and offshore facility is subjected to a 6-month inspection. During this comprehensive test, an inspection team tests each safety device and piece of equipment as required by the OCS Orders. If the device or equipment malfunctions, it must be repaired or replaced. During a typical inspection, approximately 650 items are tested at a facility. All malfunctioning equipment and incidents of noncompliance

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