According to well records with the State this well sustained a leak in 2012. Records state "packer is leaking. Packer must be repaired and casing." That document is dated May, 3, 2012. A handwritten note in the record states "No survey conducted because actively leaking backside when injecting, Seneca will re-work then resurvey, oil is generated from backside." Then there is a document/report showing repair work was completed on November 11, 2012. All tubing was replaced. Then the DOGGR inspected signed off on the well on April 4, 2013.
The record also contains a notice from DOGGR in Dec. 2011 notifying Seneca the well is noted as Active in the records, but the company has failed to report the injection pressures as required. Then before that in July of 2010, DOGGR had sent another document to Seneca notifying them the mechanical integrity test (MIT) survey as required was "overdue." The record does contain emails from an engineer with Seneca dated May 2009, where he states tests are being scheduled and he confirms which tests are required. He notes that this well requires a "water injection survey."
The record shows in 1991 there were issues with the hydrostatic pressure and the well was to be shut in by Jan. 1 1992. Other information in the well involves fresh water in the area.
The well record also contains documents showing at that time notices were printed in the local paper when a well was going to be converted. The notice was to seek public comment and input
Here is the letter dated Oct. 15 regarding the permanent closure of the injection wells:
Top state oil and gas regulator says to notify Sacramento of any deficiencies seen in coordination with local Ventura County agencies. Putting transparency and oversight at the forefront of their Renewal Plan, the California Division of Oil, Gas and Geothermal Resources (DOGGR) is aimed at fixing recognized gaps in oversight of oil and gas operations in the State.
“The Division (DOGGR) hasn’t owned up to its responsibility as regulator in the past,” said Steven Bohlen, State Oil and Gas Supervisor with DOGGR. He said DOGGR is “now moving towards doing that.”
The renewal plan is subtitled “Changing past practices to usher in a new era of oil and gas regulations.” Bohlen also said the local district deputies “work hard to maintain contact” with the local governing bodies who issue the land use permits and zoning approvals for oil and gas activity in cities and counties. Bohler said he has seen evidence of DOGGR District 2 (Ventura County) Deputy, Bruce Hesson, working closely with the Ventura County Planning department, he said “but if deficiencies are seen in that local coordination, bring that to our attention.”
“The Renewal Plan is an ongoing, four year effort to correct past problems and to create a regulatory program that ensures public health and the environment are protected while we produce oil in California,” said David Bunn, Director of the Department of Conservation (DOC). DOGGR is a division of the DOC.
Bohler and Bunn emphasized some aspects of the plan are in progress, and may take a few years to fully implement. According to the Renewal Plan document presened to the Legislature there are four main themes DOGGR will be focusing on as it revamps it’s regulatory procedures – “regulatory overhaul, new regulations for new realities, modernized data management, ensuring a high quality workforce.”
The internal audit was conducted as mandated by Senate Bill 855, which required a report be presented each January until 2015. The last time the report was provided was 2011. This report includes the “past due” data and pursuant to SB 55 focuses on the Underground Injection Control (UIC) program operated by DOGGR.
DOGGR regulates Class II injection wells in the State. These wells are used to inject fluids “associated with oil and natural gas production operations.” According to the DOGGR website “most of the injected fluid is brine that is produced when oil and gas are extracted from the earth.” These wells can be designed as disposal wells only, simply to dispose of that produced water, or to enhance oil and gas production from a nearby well. In Ventura County there are about 400 injection wells under private operation and one commercial injection disposal well located in Oxnard.
One aspect of the Renewal Plan is to ensure the project approval letters (PAL) issued by DOGGR, which govern the operation of injection wells, are complete.
“Project Approval Letters are supposed to be all inclusive about what is and what is not allowed in each project,” said Bohlen. The internal audit found these PAL’s often lacked “clarity as what operations were approved and under what conditions the project is required to operate.”
The audit also identified gaps in regulations pertaining to permitting and enforcement, inadequate staffing, poorly organized records, inconsistent permitting, monitoring and enforcement of well construction and operation. And it found the need for updated “methods to ensure injected fluids are confined to a project area,” and not leaking into geologic zones not targeted by the project.
This renewal plan is presented in the wake of a RICO racketeering lawsuit filed by Kern County farmers and residents naming former heads of DOGGR and the Governor. The lawsuit claims those named created an Enterprise aimed at helping the industry get done, what they wanted to get done, and setting public health and environmental protection aside. Mark Nechodom, the former head of the DOC, is named in the suit. He resigned the day after the suit was filed in June of this year. Here is more information on that lawsuit and a link to the full complaint is at the bottom of the story: http://globenewswire.com/news-release/2015/06/03/741916/10137097/en/Kern-County-Group-Files-RICO-Lawsuit-Against-Governor-and-Oil-Companies.html
“We analyzed past and present regulation of underground injection and find that the permitting unit – which was created over 50 years go – has struggled and sometimes failed to embrace a transparent enforcement process. We need change,” said Bunn. “Our Renewal Plan goes beyond fixing the problems of the past and creates and adaptive, effective program that puts first California’s public safety and environmental health.”
The plan document can be viewed at: ftp://ftp.consrv.ca.gov/pub/oil/Publications/Renewal%20Plan%2010-08-2015.pdf
The report letter:
On Wednesday at 4:00 and then on Thursday at 2:00 Ventura County Planning is processing two different applications for Mirada Petroleum of Santa Paula. They are a relatively small oil and gas operator with a few dozen wells in and around the Upper Ojai Valley.
Project 1- LU15-0060 (Nesbitt lease) Mirada has applied to "reactivate" three wells they promised to abandon in 2013 (and for use of K road). Abandoning those wells was a condition of a permit they were granted (in 2013) for more wells in another spot.
That scoping hearing for a Subsequent EIR is set for
Wednesday, October 7 at 4:00 pm
in the Santa Cruz Conference Room
at the Government Center on Victoria.
NO decision is made at this meeting. Here is a link to the info on that meeting/project:
link to notice of preparation and scoping hearing: http://www.ventura.org/rma/planning/pdf/nop/PL15-0060_NOP_KB.pdf
Link to CUP from 2013, with Condition 27 showing wells MUST be abandoned : http://vcportal.ventura.org/rma/planning-archives/pdf/meetings-agendas-archives/PD/2013/04-25-2013/LU11-0041.pdf
Project 2: PL13-0158 (Agnew Lease) Mirada has applied for three new wells, one redrill of an existing well, 25 more years, and use of Koenigstein Road.
The Planning Director hearing is set for
Thursday, October 8 at 2:00 pm.
in Santa Cruz Conference Room
at County Government Center
staff report: http://www.ventura.org/rma/planning/pdf/meeting%20agendas/PD/2015/10-08-15_KB_PL13-0158.pdf
The County planner for both projects is Kristina Boero, she can be contacted at: firstname.lastname@example.org, ph# 805/654-2467