DOGGR Order No. 1118
Although the Division of Oil, Gas, and Geothermal Resources (DOGGR) and the California Public Utilities Commission (CPUC) have concurred that the prohibition on injection at the Aliso Canyon natural gas storage facility should be ended, the Southern California Gas Company must meet requirements specified in the State Oil & Gas Supervisor's Formal Order No. 1118 before and after injection commences. The requirements include the tests and temporary actions that follow.
Immediately before injection resumes
- At least once during the two-week period prior to resuming injection, conduct a flight with an appropriately equipped aircraft downwind of the facility to measure total site methane emissions.
- At least once during the two-week period prior to resuming injection, complete a leak survey for the entire facility with all results reported to the CPUC and DOGGR within three days of completion and prior to resuming operations.
After injection resumes
- Complete a leak survey for the entire facility within 72 hours after resuming injection operations, with results reported to the CPUC and the California Air Resources Board (CARB) within three days of completion of the survey.
- In addition to the daily monitoring for leaks required under DOGGR regulations, complete leak surveys for the entire facility immediately after one month of injection operations and quarterly thereafter for one year (five surveys total), with results reported to the CPUC and CARB within seven days of completion. After the first year, leak surveys must be completed in line with applicable CARB regulations.
- Report daily reservoir pressure estimates to the CPUC and DOGGR during the first 30 days of resuming injection. Report daily reservoir injection and withdrawal volume measurements to the CPUC and DOGGR during the first 30 days of resuming injection.
- Report average daily tubing and annulus pressure measurement to the CPUC and DOGGR during the first 30 days of resuming injection.
- Within five working days after resuming injection, provide DOGGR with a
work plan for completing the appropriate testing protocols or plugging and abandoning each well that was isolated. The work plan shall provide for monthly status updates to DOGGR.
- If DOGGR identifies any additional data gaps in the project file, the operator shall address the data gaps within 30 days of this order.
- Conduct two flights with an appropriately equipped aircraft downwind of the facility to measure total site methane emissions. The two post-injection measurements must be within one week of each other. If both measurements show the site to emit below 250 kg CH4/hour, then no further flights will be required. If the measurements suggest that there are leaks, the flights must continue until the leaks have been fixed, no new leaks have been found, and emissions are below 250 kg CH4/hour. The exact timing of the flights will be dependent on meteorology allowing for the flights to make successful measurements of total methane emissions from the site.
- Within 10 working days after resuming injecting, provide DOGGR with a
work plan for completing the seismic risk study to the satisfaction of DOGGR using a third-party consultant approved by DOGGR and National Laboratories. At a minimum, the study must include a Probabilistic Seismic Hazards Analysis, a Probabilistic Fault Displacement Analysis, and a completed evaluation of any eventual mitigation measures. The work plan shall identify the date that the study will be completed and shall provide for monthly status updates to DOGGR.