Comment Log Display

Regarding Section 95153(v) – Produced Water Dissolved CO2:  

1.	The first line says: “Produced Water Dissolved CO2.  The
operator must calculate dissolved CO2 and CH4 in produced water as
follows:”  The remainder of the section does not mention CH4.  Are
CH4 emissions required to be reported or not?

2.	Item (3) provides an exemption for “EOR operations that route
produced water from separation directly to re-injection into the
hydrocarbon reservoir in a closed loop system without any leakage
to atmosphere”.  

    a.	Section 95102(a)(128) appears to define “EOR” to include
water flooding.  Is this a correct interpretation?

    b.	Since no system is 100% leak free 100% of the time, what is
the definition of “a closed loop system without any leakage to the
atmosphere”?  Can such a system include a water storage or surge
tank that is connected to a typical oilfield vapor recovery system
upstream of the re-injection pumps (and which may vent to
atmosphere via a pressure relief valve when process conditions are
abnormal)?  Does a system ((even if it does not include any tanks)
qualify if it has an occasional leak (e.g., water with dissolved
gases dripping from a valve stem or flange)?