Review of the Programmatic Environmental Assessment of the Use of Well Stimulation Treatment on the Southern California Outer Continental Shelf (EA)

In February 2016 the Bureau of Safety and Environmental Enforcement and the Bureau of Ocean Energy Management (overseeing the Pacific Outer Continental Shelf Region) released a draft Programmatic Environmental Assessment (EA) of the Use of Well Stimulation Treatments (WST) on the Southern California Outer Continental Shelf. The Environmental Defense Center asked Blue Tomorrow to conduct a third-party review of the draft EA over concerns that the conclusions drawn in the document, that no significant impacts are likely to occur from WST’s, were not justified or based on non-conclusive evidence. Blue Tomorrow highlighted four main points during their review of the document and supporting literature that need to be addressed before it can be determined whether or not significant impacts are likely to occur from WST’s; these included: 1) evaluation of discharge toxicity focuses on chemistry of WST injection fluids and not the composition of flowback fluids, which are what is being discharged, 2) ecological impacts from discharges of WST flowback fluids have not been studied,  3) many constituents in WST have unknown toxicity, and 4) there is insufficient justification for the determination that whole effluent toxicity (WET) testing required through the NPDES permit will limit the risk from WST discharges.

 

Oil platform in the Santa Barbara Channel off the Southern California Coast. The Environmental Assessment addressed impacts from well stimulation treatments being conducted at this platform and or similar ones nearby.

Oil platform in the Santa Barbara Channel off the Southern California Coast. The Environmental Assessment addressed impacts from well stimulation treatments being conducted at this platform and or similar ones nearby.