Frequently Asked Questions
- Approvals Required
- Environmental Review
- Fracking and Earthquakes
- Mitigation Bank
- Oil Operations, Removal and Abandonment
LCWA is not a co-applicant. BOMP is applying for the permits; LCWA will cooperate by signing applications involving its property. Pursuant to city policies regarding applications, a land owner can consent to be included in an application for city review without being a co-applicant. In August 2015, The LCWA Board approved a Term Sheet to allow BOMP to submit applications involving its property. In August 2016, the LCWA Board approved and signed an option agreement to allow for the exchange of the 154-acre Synergy site for the 5-acre LCWA site.
Located on the opposite side of Studebaker Road from the wetlands and Steamshovel Slough, the 5-acre LCWA site is isolated from the major wetlands area. The Option Agreement, approved in August 2016, involves the exchange of the LCWA site for the 154-acre Synergy site where wetlands are located. Initially, LCWA would receive the northern 76 acres of the Synergy site, which contains the wetlands and Steamshovel Slough. Ultimately the entire Synergy site will be transferred to the LCWA.
The Project provides a unique opportunity to restore a major portion of the Los Cerritos Wetlands currently in private ownership and ultimately convey those acres into public ownership. It is expensive to acquire, restore and maintain wetland habitat areas. The Project helps LCWA accomplish its goals of wetlands restoration and protection as well as improved public access and education by providing a Visitor’s Center and a public trail along the wetlands.
The 33-acre property is leased to LCW Oil Operations, LLC; Synergy currently operates 13 oil wells on the property. Long term, these oil wells and associated tanks and pipelines will be removed and abandoned, pursuant to a Surface Use Agreement (SURGE) between the City and LCW Oil Operations, LLC. Separately a pipeline system to house pipelines for oil and utilities will be constructed on the City property to connect the Pumpkin Patch site to the LCWA site.
The Synergy oil production area has been in operation since the 1920s. As the oil field was developed, and oil operations changed and improved over time, certain facilities were no longer needed. Some of these facilities, e.g., pipelines and tanks, remained on site, but were no longer supporting the oil production activities. Within 3 years following acquisition of all permits and entitlements, all tanks on the Synergy and City properties will be removed. Also within 3 years, approximately 95% of the above-ground pipeline will be removed from the Synergy site, City property and the Pumpkin Patch. All 53 existing wells will be removed over time. After receipt of the building permit for the proposed office on the Pumpkin Patch site 75% of the legacy oil operations will be reduced. Additionally, if a well does not produce one barrel of oil per day for 18-months the well would be removed. Half of the wells will be removed within 20 years following establishment of the new office facilities, and the remaining wells will be removed within 40 years. As wells are abandoned, access roads and pipelines will be removed when no longer needed to support those removed operations.
Ownership is in concurrence with the creation of a mechanism, condition of approval, written agreement, or a covenant to address the removal of wells, which will occur over a 40-year period, and which will commence upon the issuance of the Consolidated Coastal Development Permit.
It is estimated that there is over 66,000 linear feet of pipeline currently on the Synergy site, approximately 21,000 linear feet on the City property and approximately 1,000 linear feet on the Pumpkin Patch. Approximately 95% of all above-ground pipeline (a combined 83,600 linear feet – nearly 16 miles) will be removed within 3 years after receiving entitlements and permits, providing an early benefit to the land both aesthetically and logistically making more land available for restoration.
Preservation, protection and enhancement of the natural habitat is our primary goal. Synergy’s oil production areas contain existing degraded wetlands habitat which can be restored and significantly enhanced through the removal of the existing oil facilities. Another important goal is to reduce the liability of having oil operations near habitat; implementation of the restoration plan, with the proposed sheet pile walls and berms, will serve to protect the natural habitat. Lastly, it is more cost effective to consolidate new oil operations in smaller, more compact locations.
Each well costs approximately $5 to $7 million to drill. Construction of the facilities and wetlands restoration is estimated to cost approximately $140 million.
Oil production in the area began nearly 100 years ago, and the existing operations rely on technology and standards that are decades old. Advanced drilling technologies as proposed by the Project will allow for more efficient production with less environmental impact.
The sites will be designed to capture spilled liquids and rainwater, to be collected and handled on-site, with no off-site drainage.
During drilling, all wells will be equipped with Blowout Prevention Equipment (BOPE) systems to prevent the uncontrolled release of formation fluids. BOPE also allows for the shut off of flow to prevent spills and releases of materials. The Project’s wells will be designed and operated with American Petroleum Institute standards to ensure well integrity. Wells will have multiple layers of casing and cement, providing effective barriers for containment of well fluids and preventing contamination of freshwater aquifers. Additionally, wells will be continually monitored to ensure adequacy of the casing and cement, and to make certain that pressures are maintained.
To demonstrate that the pipe, fittings and weld sections will maintain mechanical integrity under pressure, hydrostatic testing of the pipeline will be performed after construction and prior to startup. Once operational, the pipeline would be regularly inspected and maintained.
During operation of the Project, all tanks will be equipped with leak detection systems, overfill protection, instrumentation to monitor and control levels, and instrumentation to control temperature and pressures. The tanks will also be provided with pressure relief valves.
The Project will also be equipped with computerized control, monitoring and communication systems. In general, these systems will be designed to monitor and control all process equipment that will operate within the facilities. The facilities will also be equipped with gas and fire detection systems and a fire suppression system.
An Emergency Response Plan will be prepared to specify measures to be taken in emergency situations. All measures will be detailed in the EIR. In addition, each facility will have safety guidelines in place that correspond specifically to each site (i.e., the design on Pumpkin Patch will prevent spillage into the San Gabriel River Channel).
The 120 new wells will include not only oil production wells, but also water injection and source wells. It should be noted that at present there is no water injection occurring, however, water injection and source wells will be required for the Project.
The plan for the drilling of wells calls for drilling one well at a time. The drilling process for either an injection well or a producing well requires approximately three months. Remaining wells are drilled in subsequent three-month periods. The plan calls for the drilling of all wells in a timely manner, however, due to the time to drill a single well, drilling of all wells will take place over a considerable amount of time.
Both. The existing wells rely on older technology and use more electricity as compared to the proposed wells. The existing wells depend on pump jacks (the “horse heads” you see now) to bring oil to the surface. The proposed production wells will not rely on pump jacks, rather, will use electric submersible pumps (ESPs), which are pumps located inside the well. As ESPs are located downhole, they are not visible at the surface.
There has been no fracking at the Project sites since operations began in 1929, nor does the Project identify fracking in the current proposal.
For more detailed information regarding fracking, please see the Well Stimulation Treatments White Paper.
There is a broad concern that oil production and water injection activities can result in man-made earthquakes, as has been happening in the central United States, particularly in Oklahoma. Will we start to see more earthquakes as a result of the fluid injection associated with the proposed Project?
Water is a byproduct of oil production and must be disposed. When this produced water (or wastewater) is injected subsurface, it can be injected back in to the production formation or it can be disposed of below the production formation. Seismologists are in general agreement that the disposal of water below the production formation into a layer in hydraulic communication with fault-laden basement rock presents a potential risk for triggering seismicity.
Whereas Oklahoma has experienced a rapid increase in earthquakes due to their wastewater disposal practices, California has rarely experienced man-made earthquakes related to water injection over decades of oil production activity.
The water produced during the Project’s oil extraction operations will be injected back into the production formation via the water injection wells. This is in contrast to Oklahoma’s problematic wastewater disposal practices, wherein water is disposed well below the production formation. Additionally, the Project’s water injection practices will serve to maintain pressure within the production formation, as the injected water replaces the volume of fluids extracted. The proposed Project’s water injection practices are the same as has been practiced on the Southern California oil fields since the late 1930s and are not expected to induce seismicity.
For additional information, please refer to the Induced Seismicity White Paper.
In California, oil production has occurred for at least 140 years. Throughout this time, zones of high oil production have been found predominantly in fault zones, in close proximity to fault lines. Commonly, it is the fault that splits the rock and “releases” the oil formed deep within the Earth over millions of years, bringing it close enough to the surface to be extracted. The proposed Project intends to produce oil from the Seal Beach Oil Field. Oil production began in this field in the early 1920s and continues today.
The Project’s wells will be designed for the specific geology and operated with American Petroleum Institute standards to ensure well integrity. Wells will have multiple layers of casing and cement, providing effective barriers for containment of well fluids and pressures throughout the life of the well. Additionally, wells will be continually monitored to ensure adequacy of the casing and cement, and to make certain that pressures are maintained.
Currently in California, there are a number of fault crossings by pipelines and wells, including crossings of the very active San Andreas Fault. The connection pipeline is being designed by an engineering expert who specializes in designing infrastructure and utilities which cross faults. The line is being designed to withstand a 7.5 magnitude earthquake with a 5.5’ displacement along the fault. Safety mechanisms including emergency valve shut offs, etc. will be incorporated into the design.
Hydraulic fracturing, also called fracking, is a drilling technique wherein water, sand (or similar) and a small amount of additives are pumped down the well bore under high pressure. This process either causes existing fractures to expand, or new fractures to form. After the fractures are created, the water and additives are drawn back up the well bore to the surface. The sand remains in the new or expanded fractures and serves to prop them open, creating a pathway for the oil and gas to enter the wellbore and flow into the well.
The current Project proposal includes the drilling and operation of up to 120 oil production, water injection and water source wells from two sites. Throughout the life of the Project, well maintenance and workover operations would be periodically necessary to sustain production from the wells. Typical routine well maintenance activities include, but are not limited to, repair or replacement of wearable parts and maintenance of downhole components. Typical workover operations likely involve downhole repairs and may involve pulling tubing and/or replacing downhole pumping equipment.
Neither the Project’s water injection practices nor well maintenance activities constitute well stimulation treatments, such as fracking, as defined in the amended Public Resource Code. Specifically, well stimulation treatments do not include, “steam flooding, water flooding [water injection], or cyclic steaming and do not include routine well cleanout work, routine well maintenance, routine removal of formation damage due to drilling, bottom hole pressure surveys, or routine activities that do not affect the integrity of the well or the formation.” [Public Resource Code Section 3157 (b)]
The current Project proposal does not include the use of well stimulation treatments, as defined above.
For additional information, please refer to the Well Stimulation Treatments White Paper.
As paraphrased from the U.S. Army Corps of Engineers’ website: Mitigation Banks are sites approved by the Corps and other state and federal agencies to sell compensatory mitigation credits for projects resulting in unavoidable impacts to waters of the U.S., waters of the State, and other regulated jurisdictional resources.
A proposal for a Mitigation Bank must undergo review by an Interagency Review Team (IRT), which is comprised of a number of state and federal agencies, including the California Coastal Commission, U.S. Army Corps of Engineers, U.S. Fish and Wildlife Service, National Marine Fisheries Service, California Department of Fish and Wildlife, and the Environmental Protection Agency. The IRT reviews all aspects of the bank from the restoration plan to the service area, to crediting. Once the technical aspects of the bank are approved, the IRT, in conjunction with the mitigation bank sponsor, which is Synergy Oil & Gas, LLC, will finalize the Banking Enabling Instrument, which will allow credits to be sold on a scheduled and phased basis. This is a process that has seen success throughout the southland both for priority projects for the Ports of Los Angeles and Long Beach as well as for private development projects where mitigation in a mitigation bank can be more significant than on a piecemeal basis.
The costs of restoring degraded wetlands to create a mitigation bank are paid by the mitigation bank sponsor; in this case, Synergy Oil & Gas, LLC. Once the IRT has established the amount of “credits” that can be used to mitigate wetland impacts on other properties, the bank operator can market and sell those credits on a phased release schedule. Restoration activities along with monitoring of performance standards in Year One have to be completed in order for additional credits to be released. The significant initial investment of restoring the wetlands is held solely by the mitigation bank sponsor, as is the risk that credits are not sold. The document by which the IRT establishes the amount of credits and the type of wetland habitat credits that can be sold by the bank is called the Bank Enabling Instrument. The money that is paid by third parties needing to mitigate offsite wetland impacts is used to offset the initial investment made by the bank sponsor to create the bank and to help pay for the costs of ongoing management of the restored wetlands.
A long-term management plan will be approved by the IRT as part of the process to establish the mitigation bank. The costs of the restoration are anticipated to be funded by the bank developer which will be reimbursed through the sale of mitigation bank credits. The cost of long-term management and operation of the mitigation bank will be funded through a non-wasting endowment. Please refer to the White Paper entitled Adequacy of Endowment for the Long Term Management of the Mitigation Bank .
Credits can only be sold to purchasers who have obtained the regulatory agency permits (e.g., 404 Clean Water Act Permit, 1602 Streambed Alteration Agreement, CDP, etc.) that allow for compensatory mitigation to be in the form of mitigation bank credits. Each permit is handled and negotiated individually on a project by project basis by public jurisdictions including cities, counties and the Coastal Commission. The impacts associated with each project cannot be anticipated as each project will have to demonstrate maximum avoidance of impacts before the permit can be issued.
The bank sponsor (in this case, Synergy Oil & Gas, LLC) must actually pay for the costs of creating and restoring the wetlands that form the mitigation bank in the first year of its implementation. The cost associated with this effort is the lion’s share of the overall restoration cost. The sale of wetlands mitigation credits in the bank will certainly help offset the investment made by the bank developer to create the mitigation bank, but the bank sponsor bears the burden of continuing the maintenance and monitoring requirements even if no credits are sold. If there is no market for the credits, the bank sponsor’s investment will not be recouped. The bank sponsor is essentially undertaking a significant risk by investing its money to create the bank with the goal of seeing its investment offset through the sale of credits.
The location of other banks within the nation and specifically, in Southern California, can be viewed at: http://www.spl.usace.army.mil/Missions/Regulatory/Mitigation.aspx.
An Interagency Review Team (IRT) is in place for this project and will oversee all aspects of establishing the mitigation bank. The IRT is composed of representatives from the California Coastal Commission, the U.S. Army Corps of Engineers, U.S. Fish and Wildlife Service, National Marine Fisheries Service, California Department of Fish and Wildlife, and the Environmental Protection Agency.
BOMP has contracted with Glenn Lukos Associates to undertake processing of the mitigation banking enabling instrument with the IRT. Glenn Lukos Associates is a recognized leader in “wetland” and other water-related permitting, wetland delineation, habitat restoration design, mitigation implementation, mitigation monitoring, biological surveys, and endangered species coordination. They have a staff of 21 professional Regulatory Specialists, Habitat Restoration Specialists and Biologists. Thienan Ly Pfeiffer is the lead for the mitigation banking element of the project and Tony Bomkamp and Sheri Asgari are the restoration specialists. The firm credentials and the bios for the team are available upon request.
The City of Long Beach is responsible for preparing the CEQA analysis and has determined the need for an Environmental Impact Report (EIR). The scoping session to allow for the first input on what the EIR should cover was held at Kettering School on May 11, 2016. The City directed their consultant on the preparation of the EIR which includes analysis of the issues raised at the Scoping Session. The City has made the draft EIR available for public review for a period of 45 days during, July 24 and September 6th, 2017, which time the public can submit written comments on the proposed project, and the City’s environmental analysis. To be placed on a notification list to be notified when the DEIR is available, contact Craig Chalfont, City of Long Beach Development Services Department, Planning Bureau, at: firstname.lastname@example.org. Additionally, on August 17th the City will host a study session at the Planning Commission meeting. The EIR and the requested project entitlement applications will proceed through the public hearing process at the City of Long Beach. Hearings will be held by the City Planning Commission and City Council. After the City has approved the entitlements, the project will be reviewed by the Coastal Commission who will act on the Local Coastal Program Amendment and Coastal Development Permit.
There will be truck traffic during construction. Once the facilities are operational, oil will be transported off-site through existing pipelines (Plains All American Pipeline and Crimson Pipeline) to off-site storage tanks and excess natural gas will be sold via the grid to Long Beach Gas and Oil or SoCal Gas, not trucked off site.
Sea level rise, coastal erosion and flooding have been a major concern of local agencies as well as the California Coastal Commission. The Commission has provided comments to the City that these issues should be examined during the City’s CEQA process. In addition, when the project applications are submitted to the Coastal Commission, it too, will analyze the impacts of sea level rise, coastal erosion and flooding on this project. Upon approval of the project and issuance of a Coastal Development Permit from the California Coastal Commission, grading will occur in strategic locations within the 76-acre mitigation bank site to enhance tidal exchange from the Steamshovel Slough and a new 9 foot high berm will be constructed on existing disturbed areas to protect the existing oil facilities and the restoration area from potential sea level rise.
The City of Long Beach, the lead agency for the project under the California Environmental Quality Act (CEQA), has discretionary authority over the proposed project as follows:
- SEADIP Amendment
- Oil Operating Area Boundary Change
- Site Plan Review for Pumpkin Patch
- Site Plan Review for the LCWA Site
- Site Plan Review for the Synergy Oil Field
- Oil Drilling Permit
- Oil Well Permit
- Certificate of Compliance for the LCWA parcel
- Certificate of Compliance for the Synergy 78-acre mitigation bank area, Visitor’s Center, parking lot, and trails
- Certification of the Environmental Impact Report (EIR)
- Local Coastal Program Amendment
The amendment to the Southeast Area Development and Improvement Plan (SEADIP) would allow the following activities:
- The designation of the Synergy site as open space and passive recreation uses upon completion of the wetlands restoration work
- Oil production uses on the Pumpkin Patch site and the LCWA site
- Oil tank height approvals on the LCWA site
- An amendment to the City’s Oil Map to include the LCWA site and Pumpkin Patch site within mapped Oil Production Areas
- An amendment to the City of Long Beach Local Coastal Program (LCP) to include the Synergy site in the City’s LCP; the designation of the Synergy site for oil production (as an interim use) as well as open space and passive recreation uses; the designation of the Pumpkin Patch site for oil production uses; and the designation of the LCWA site for oil production uses.
Other Responsible Agencies include:
- U.S. Army Corps of Engineers
- California Coastal Commission (which will hold public hearings; issuance of a permit is required to commence the project)
- California Department of Fish and Wildlife
- U.S. Fish and Wildlife Service
- National Marine Fisheries Service
- Los Cerritos Wetlands Authority
- South Coast Air Quality Management District
- Los Angeles Regional Water Quality Control Board
- Division of Oil Gas and Geothermal Resources
The City of Long Beach suggested that because the issues to be addressed for these four properties were limited to just two land use issues (habitat conservation and oil production) and would be considered on a coordinated basis, they could be reviewed independently by the City and did not have to be part of the larger SEASP process which involved more properties and consideration of many other land use issues besides habitat restoration and oil production.
BOMP is working with the operator of the Pumpkin Patch and Christmas Tree Lot to help identify new locations for these community events. The operator has indicated a willingness to work with our team in that regard, recognizing the benefits of consolidating the oil production away from the significant wetlands area.