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Dr. Hugo A. Loáiciga, P.E.
Professor of Hydrology and Water Resources, Dept. Geography/ UCSB
Santa Barbara California 93106 USA
hugo@geog.ucsb.edu tel 805 450 4432 /fax:805 893 2578
UNIVERSITY OF CALIFORNIA Santa Barbara
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BERKELEY • DAVIS • IRVINE • LOS ANGELES • MERCED • RIVERSIDE •
```````````````````````````SAN FRANCISCO SANTA BARBARA • SANTA CRUZ
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SAN DIEGO •
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DEPARTMENT OF GEOGRAPHY 1832 Ellison Hall
Santa Barbara, California 93106-4060
Phone: (805) 450-4432
Fax: (805) 893-2578
http://www.geog.ucsb.edu/~hugo
DATE: May 24, 2010
TO: Mr. Ted Rhodes
Co-Chair, Citizens Against Paredon
180 Ocean Avenue, Carpinteria, California 93013
FROM: Dr. Hugo A. Loáiciga, Professor/UCSB
hugo@geog.ucsb.edu; tel: 805 450 4432
SUBJECT: My comments about (1) the Proposed Final Environmental Impact
Report: Venoco Paredon Project (PFEIR:Venoco Paredon Project) dated March
2008, and prepared by Marine Research Specialists (MSR) for the City of
Carpinteria, and (2) the August 27, 2009, letter by David Gardner (Senior Vice
President, Fugro West, Inc.) to Charles Hamilton, General Manager of the
Carpinteria Valley Water District (CVWD).
Following my meeting with you and several other members of Citizens Against
Paredon on May 7, 2010, to discuss the deficiencies, inaccuracies, and errors of the
PFEIR:Venoco Paredon Project, I have prepared a set of technical opinions
regarding the proposed Venoco Paredon Project and the cited related documents.
These opinions are written below. Please do not hesitate to contact me regarding
the contents of this memorandum. I could expand my analysis of any of the
opinions listed in this memorandum upon your request.
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1. I am of the opinion that the proposed Venoco Paredon Project , if permitted and
built, would bring about several Class I impacts (significant adverse impacts that
are unavoidable) to the City of Carpinteria and surrounding areas.
2. The PFEIR: Venoco Paredon Project fails to identify threats to and Class I
impacts on water resources (including surface water and groundwater),
geotechnical resources, and various environmental resources and recreational
resources that would arise if the Venoco Paredon Project were permitted and built.
3. The PFEIR: Venoco Paredon Project does not provide a proper description of
the 35 wells that would be drilled and constructed to extract petroleum (crude oil)
and natural gas from the Paredon (geologic) reservoirs. This description is needed
to assess the performance and operability of these wells during the life of the
proposed Venoco Paredon Project. The following information is missing in the
PFEIR: Venoco Paredon Project regarding extraction wells:
* the wells’ layouts and their relation to geologic formations and faults in
properly drawn elevation cross sections from the processing facility to the
source reservoirs;
* their length, depth, and cross-sectional construction details.
Section 2.5.1 Drilling, pages 2-21 – 2-30, including Figure 2-8, provide only a
generic detail of well design and construction that is insufficient to assess the
performance of the well subject to fluid pressures. The PFEIR states on page 2-28,
first paragraph that:
“A BOP (Blowout prevention) system would be placed on each wellhead during
drilling and removed once the well was established”.
This statement raises questions:
Why would the BOP be removed once a well was established? Couldn’t there be
blowouts in established wells, just as we see it happening in British Petroleum’s
(BP) well in the Gulf of Mexico?
What preventive measures against pipe ruptures and fluid leaks in the subsurface
would be taken? The PFEIR refers to a temporary BOP system at wellheads, but
well failure in a highly seismic area (like Carpinteria) could easily happen
underground.
4. Regarding fluid pressures in the wells, the PFEIR states on page 2-28, first
paragraph, that:
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“The Applicant indicates that wellhead pressures (pressure at the wellhead where
the BOP is situated) would be a maximum of 2,500 psig (pounds per square inch
gage)”.
How was this maximum pressure obtained?
5. In section 4.1.1.5 Existing Facility and Pipeline Risks, page 4.1-12, the PFEIR
delves into the matter of Current Operations and Risk Analysis, and states on page
4.1-12, fourth paragraph, that:
“Offshore spills are complicated by the influence of a range of variables, such as
crude oil temperature and density, the depth of the pipeline and leak geometry.
Much of the offshore pipeline is deep enough that a leak in the pipeline would
produce minimal release volumes. This is due to the pressure of the ocean water
actually being greater that the pressure inside the pipeline.”
The former statement is a naïve conjecture that ocean water pressure can act as a
shield against deep oil leaks: if this were the case, how can it be that large amounts
of oil are leaking from BP’s 1-mile deep well in the Gulf of Mexico?
6. The Carpinteria Groundwater Basin’s (CGWB) aquifers extend from their
terrestrial boundaries into geologic formations lying underneath the Pacific Ocean
(see PFEIR: Venoco Paredon Project, page 4.6-2, section 4.6.1.2 Groundwater).
This is a critical fact because the proposed Venoco Paredon Project extraction
wells (up to 35 in total) would threaten groundwater and surface water resources in
the event of very likely well leaks. This is so because well leaks would introduce
pressurized hydrocarbons into surrounding aquifers (and formations) that would
migrate upwards, thus contaminating groundwater and surface waters, including
oceanic waters. Mr. David Gardner’s letter ignored the actual stratigraphic
characteristics of the CGWB’s aquifers. A misleading statement in this regards is
found in Mr. Gardner’s letter, page 2, first paragraph:
“The proposed oil wells, given their depths, proposed location, and subsurface
orientations have no hydraulic connection to the ocean, thus there is no risk that the
project would create or induce seawater intrusion into the shallow groundwater
aquifers of the basin”.
This statement by Mr. Gardner is contrary to fundamental hydrogeologic principles
and outright incorrect.
7. The PFEIR: Venoco Paredon Project states in section 4.6.4, page 4.6-14, that
“Three injection wells have been proposed for disposal of produced water, drilling
mud, and drilling fluid (waste)”. This injection proposal is inadmissible in the
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CGWB’s aquifers, which serve important water supply and environmental
functions, as they are connected to marshlands, and other surface water bodies that
provide vital biological, recreational, and aesthetic services. Yet the
PFEIR:Venoco Paredon Project fails to identify the proposed injection with what it
is, that is, a Class I impact. Mr. Gardner’s letter, page 1, bottom of the second
paragraph refers to this proposed injection of wastes into the aquifers as “a
standard practice of oil operations”, showing disregard for environmental impacts.
It is this kind of attitude that led to the immense damage being caused in the Gulf
of Mexico by the largest oil blowout in US history, where incompetence,
negligence, and miscalculations by oil operators and regulators are exerting and
will exert incalculable damage to biologic, recreational, and aesthetic resources.
8. The PFEIR: Venoco Paredon Project states on page 4.6-15 (section 4.6.4),
second paragraph that: “The southern portion of the Carpinteria Groundwater
Basin underlines a portion of the project site and extends beneath the Pacific
Ocean. Although the proposed drilling site is located within Storage Unit 2 of the
basin, the proposed East Paredon field extends in the subsurface north of the
Rincon Creek Fault, within Storage Unit 1 (Figure 4.6-4), which is the primary
source of municipal water for the Carpinteria Valley Water District. The exact
locations of the injection wells within the Paredon Field are undetermined;
however, these wells may pass through groundwater that is used beneficially as a
drinking water source and for agricultural production. In addition, as illustrated in
Figure 4.6-5, the Vaqueros and Sespe formations are in direct contact with
overlying unconsolidated sediments of the Santa Barbara Formation, which may be
water bearing. Migration of highly saline, injected wastewater from the Vaqueros
and Sespe formations (the proposed geologic horizons to be injected) into these
unconsolidated sediments could result in impairment of water quality not only in
the Santa Barbara Formation, but also the overlying Casitas Formation, from which
most of the water is derived in the Carpinterial Groundwater Basin.”
In view of this, who in his right mind would propose injecting wastes –like the
Venoco Paredon Project does- in the Carpinteria Groundwater Basin?
9. On page 4.6-16, lines 18, 19 (section 4.6.4), the PFEIR: Venoco Paredon
Project states that:
“the produced (injection) water would be highly saline and could potentially impair
groundwater quality in the unlikely event that an injection well leaks in the area
near the groundwater.”
Actually, well leaks in the proposed Venoco Paredon Project area are not unlikely,
but, rather, almost certain to occur due to the inherent high seismicity of the region,
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which is classified by the California Building Code as a Zone 4, where the risk of
earthquakes is highest (see PFEIR page 4.7-7, top paragraph, section 4.7.2.1). The
PFEIR: Venoco Paredon Project acknowledges the high seismic risk at the project
site, but fails to translate this fact into an unmitigable impact. Specifically, on
pages 4.7.3 (last paragraph) and 4.7.4 (second paragraph, section 4.7.1.5 Faulting
and Seismicity), the PFEIR Venoco Paredon Projects states that:
“Regional onshore faults that can be expressed to cause seismic shaking at the
Carpinteria Production Facility (CPF) during an earthquake include the San
Andreas Fault located approximately 36 miles (58 km) from the site, and the Santa
Ynez/Santa Ynez River Fault Zone, approximately six miles (10 km) from the site.
Both of these faults are considered active (Dibblee 1966, Jennings 1994, CDMG
1994, 1999). The San Cayetano blind thrust fault, approximately six to seven miles
(10 to 12 km) beneath the project site, poses another seismic hazard (Namson and
Davis 1988, 1990). The offshore Pitas Point/North Channel and Red Mountain
faults, located approximately seven miles (11 km) and two miles (4 km) offshore,
respectively (Jennings 1994), are also considered active and would cause seismic
shaking at the project site during an earthquake (Foxal et al., 1995). In addition, the
Oak Ridge and Channel Islands Faults are considered offshore seismic forces
(Shaw and Suppe 1994 Sorlein et al. 2000).
Numerous east-west trending, active and potentially active faults are present in
Holocene and Quaternary terrace deposits in the Carpinteria Bluffs area (Figure
4.7-1). On the surface, the south branch of the Carpinteria Fault is at its closest
point approximately 200 feet (60 m) north-northeast of the project boundary and
600 feet (180 m) north-northeast of the proposed drilling site. Below ground
surface, the easterly extension of the project area extends across the south branch
of the Carpinteria Fault. While most documents indicate that the Carpinteria Fault
is potentially active (Santa Barbara County Planning and Development 1991; City
of Carpinteria 2003, Jennings 1994), a branch of this fault, the Railroad Fault
located approximately 1.1 mile (1.8 km) southeast of the project area, has been
classified as active (Gurrola et al., 1998, 2003); this suggest that the Carpinteria
Fault would potentially also be active”.
The third paragraph of page 4.7-4 of the PFEIR: Venoco Paredon Project (section
4.7.1.5) states that the Rincon Creek Fault is “apparently active” and cites
bibliographic references to support that classification.
Mr. Gardner’s letter dismisses the geologic evidence of earthquake risk at the
proposed project site by resorting to what he appears to believe is a regulatory
loophole, that is, by claiming that (see the letter’s page 1, last paragraph, and page
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2, top paragraph) “the faults creating the traps for the petroleum hydrocarbons are
not zoned as active faults by the California Division of Mines and Geology under
the Alquist-Priolo Special Studies Zones Act.”
The high earthquake risk and almost certain damage to wells and subsequent leaks
to the aquifers is a strong reason to reject this Venoco Paredon Project.
10. The PFEIR: Venoco Paredon Project acknowledges on page 4.7-2, last
paragraph, section 4.7.1.4, that there is risk of land subsidence in the Carpinteria
region. This would be caused by the proposed Venoco Paredon large-scale
extraction of oil and natural gas, which would lower the pore fluid pressure and
increase the effective stress in the underlying formations. Yet, this threat is
cursorily dismissed by the PFEIR. Subsidence is the drop of terrain elevation by
the extraction of subsurface fluids, be them groundwater or petroleum
hydrocarbons. In coastal areas, like Carpinteria, land subsidence could be
compounded by the rise in sea level that the State of California has identified as a
probable impact of climate change due to rising atmospheric temperatures through
the 21st century (California Department of Water Resources, 2006: Progress on
Incorporating Climate Change into Management of California's Water Resources,
Sacramento, California). The linkage between hydrocarbon extraction, subsidence,
and sea level rise was completely ignored in the PFEIR: Venoco Paredon Project.
11. In general, the mitigation measures cited in many parts of the PFEIR: Venoco
Paredon Project and concerning a variety of water resources, environmental, and
aesthetics impacts amount to wishful thinking: the PFEIR minimizes impacts and
overrates the success potential of mitigation alternatives. The PFEIR does not meet
the standard of care of a well written and researched environmental impact
assessment.
12. The August 27, 2009, letter by David Gardner ignores important empirical
facts that render the Paredon Project questionable.
Sincerely,
Hugo A. Loáiciga
Professor of Hydrology and Water Resources/UCSB
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