Southern California is now in month three of one of the country’s worst environmental disasters. In October 2015, a natural gas storage well operated by SoCal Gas sprung a massive leak hundreds of feet underground, releasing nearly 1,400 tons of gas into the air each day at its peak. Thousands of local residents impacted by noxious fumes and oily mist have been evacuated from the communities around the Aliso Canyon storage field. Because the leak is so large and technically complex, SoCal Gas has been working for months to fix it – so far without success.
In January, California Governor Jerry Brown declared a State of Emergency because of the ongoing leak. In addition to addressing the immediate disaster at Aliso Canyon, Gov. Brown ordered emergency regulations for the state’s natural gas storage industry and has directed several state agencies and commissions to prepare and submit reports and propose how to prevent similar leaks at similar sites across the state.
This month, the Department of Conservation's Division of Oil, Gas, and Geothermal Resources (DOGGR) released its draft emergency regulations, and EDF suggested important clarifications to make the rules more workable. We also provided a long list of issues not covered by the emergency rule that nevertheless must be addressed going forward (you can read our comments here). The draft is a good start, and though there is a lot more work ahead, the signs are that DOGGR is taking the right approach and heading in the right direction.
Above all else, DOGGR’s rules, both emergency and permanent, should satisfy one critical concept: well integrity. Well integrity is all about keeping wells from leaking – a complex endeavor requiring oversight (with vigorous enforcement) of design, construction, operation, testing, routine maintenance, repair, and decommissioning of wells.
The Aliso Canyon disaster has shined a light on an aging infrastructure where well integrity appears to have suffered from decades of neglect and thus poses significant environmental and public safety risks.
The draft emergency regulations are an important first step. California regulators know and EDF agrees that it is unrealistic to think that any emergency regulations will immediately resolve an issue this complex. This will be – and must be – the beginning of a long, continual effort to upgrade gas storage regulations, especially those relating to well integrity. This is true not just in California but across the country.
Thankfully, leaks of the size and duration of SS25 at Aliso Canyon are rare. Extreme leaks are dramatic and hard to miss. But even a methane leak this huge is small compared to the cumulative amount of methane pollution coming from every stage of the country’s oil and gas supply chain, from wellheads to the local utility lines under city streets. EPA estimates that each year, 7 million metric tons of methane escapes from the supply chain – about 80 times the amount that has been emitted from Aliso Canyon to date.
Preventing methane leaks from oil and gas wells is only part of the solution to the methane emissions problem – but it is an important one. If a well is built or maintained badly, it will leak.
EDF looks forward to working closely with other California stakeholders and with public officials to resolve well integrity issues and all other aspects of the methane emissions challenge. Our oil and gas staff have been working on well integrity issues for years, especially in states that have experienced tremendous growth in oil and gas production from shale formations. Texas, Ohio, and other states have favorably taken our environmentally-focused proposals into account in recent policy updates, leading to better overall outcomes. In these efforts, well integrity issues like cementing practices and pressure management were addressed. Passed in 2013, “Rule 13” marked Texas’ most significant overhaul in decades of well construction rules (including gas storage wells). According to the Texas Railroad Commission, the rule has reduced the number of blowouts across the state by nearly half.
This demonstrates that good well integrity rules can make a difference in safety and environmental performance. Well integrity includes key principles like multiple barriers of protection, appropriate safety equipment, frequent testing and maintenance, and monitoring of well conditions that might indicate potential leaks to the environment. After major gas storage disasters in Kansas and Texas, both states upgraded their gas storage regulations. California, too, will need to address these and other important technical issues as it upgrades its rules.
Given the State of Emergency in California, it is understandable that resolving the immediate crisis has taken center stage. But the solutions required to prevent another Aliso Canyon and the millions of tons of methane emissions from smaller, less dramatic leaks will not be implemented with one rule.
DOGGR must remain committed to ensuring that the state’s oil and gas laws reflect this idea of continual improvement. It’s the only way to ensure that policies meant to protect public health and safety keep pace with a rapidly changing industry. This means updating not only the policies that pertain to gas storage facilities, but also oil and gas production wells, underground injection wells for wastewater, wastewater storage facilities and other aspects of oil and gas development.
EDF works with states across the country to help implement the most forward-thinking ideas into their policies to safeguard against incidents like the Aliso Canyon gas leak, and we’re committed to working with DOGGR and other agencies, as well. Because the best way to fix a gas leak is to prevent it from happening in the first place.