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HomeMy WebLinkAbout1983-06-19; City Council; Info; Staff Recommendation and Draft OC Task Force- S;ua Dic&{o ASS 0 c LY i'T 0 N (IF G 0 W;I< s 3 I ES'1-S Suite 524 Security Pacific Plaza 1200 Third Avenue San @kcgo, California92101 (619) 236-5300 ,. July 15, 1983 TO: OCS Task Force Members FROM: Jack Koerper, SANDAG Staff SUBJECT: Staff Recommendation and Draft OCS Task Force Report htroduction - The proposed Southern California Lease Offering, February 1984, or Lease Sale No. 80, is scheduled for early next year. The Task Force has held five meetings to disctsso several issues associated with offshore petroleum development: Also, the Task Force has met with the Western Oil and Gas Association (WOGA) exploration committee and toured Platform Grace in the Santa Barbara Channel. The geographic area covered by the lease sale is outlined in Figure 1. Figure 2 depicts the industry interest in the nearshore tracts. The number in each tract represents the number of companies interested in that particulax tract. Previous Southern California lease sdes (Nos. 48, 68 and 73) have excluded the area 3 to 25 miles offshore San Diego. The purpose of the Task Force is to update the Board's OCS position which was developed five years ago for Lease Sale No. 48. Staff evaluated the information contained in the DEIS, analyzed the information presented to the Task Force, and reviewed other pertinent documents and reports relevant to the Board's position and tke issues io form its recornmendation and prepare the. draft OCS Task Force report. Staff believes that is was the responsibility of the proponents to present convincing and generally recognized information or data to change or modify the Board's previous position. Based on that analysis, it is RECOMMENDED that. the OCS Task Force recommend to the San Diego Association of Govern- ments Board of Directors that it reaffirm its policy of opposing petroleum development in the nearshore area (3 to 25 miles). Discussion The following is the rationale for the staff recommendation regarding the issues discussed by the Task Force. The format of this report is to provide a issue * statement that summarizes the Board's existing position, describe what information has beqn presented to the Task Force to address these issues, and develop a conclusionary statement as to whether or 'not a recommendation should be offered to the Board to amend its position. The last section of the report . describes the energy savings as a result of the development and conservation of local energy supplies. . I. 5 -. Issue Statement The Department of the interior in 1979 in its Final Environmental Impact Statement for Lease Sale No. 48 stated: "Tracts totally situated in water depths greater than 400 meters cannot at present be developed using conventional technology." Twenty-two (22) of the 26 tracts offered in Lease Sale No. 48 had water depths greater than 400 meters. The production of those tracts would have required the use of experimental technology in a frontier area which increases the risk of an accident. Discussion Representatives of the oil industry have stated that conventional petroleum roducing techology cannot be used in water depths greater than 400 meters P 1,200 feet) because of costs. The cost of constructing a conventional petroleum producing platform in deep water becomes prohibitive. In order to reduce the costs and safely produce the resource, the industry is in the process of developing new technologies to address this issue. At the present time, two platforms utilizing the experimental technology are being constructed and will be used in the Gulf of Mexico and the North Sea. The DEIS for Lease Sale No. 80 does not discuss this issue. Conclusion Although some progress ha?,been made by the industry to address this pyoblepif;, is apparent that the new1 kecfinofdgy is not yet operational and that1 '&iffin in water depths greater than 400 meters has significant risks associated with it. It is recommended that the Board's concern should not be changed. -63 -it / _. - -. Oil and Gas Resource Estimates Issue Statement The resource estimates for the 26 tracts offered in Lease Sale No. 48 were 30 million barrels of oil and 45 billion cubic feet of gas. When computed against the 1980 national consumption figures, these resource estimates represent only 42 hours of oil and 17 hours of gas. These estimates are not significant, and the risks associated with the develcgment of this miniscule resource axe substantial to the San Diego region. . Discussion a. . The resource estimates contained in the DES for Lease Sale No. 80 for the - nearshore area off the San Diego coast apparently are less than those estimated for Lease Sale No. 48. The estimates calculated from the DEIS are 20 million barrels of oil .and less than 45 billion cubic feet of gas. c I , , -. A- ,* One method in which a costlbenefit analysis can be prepared is to compare the costs of producing the petroleum resource to the benefit or the amount of resource. Duricg Lease Sale No. 48 in 1979, it was concluded that the estimates were insignificant to justify the production risks. Conclusion 1. \ The risks to San Diego if an accident should occur using experimental technology is very significant given th$%%&krck estimates. Therefore, the Board's concern .should not be changed. fWJ 26 . Military Operations Issue Statement *f San Diego is the Navy's principal West Cost port; it supports more than 120 ships of the Pacific Fleet. The San Diego offshore area is the principal training area for the Navy and Marine Corps. The ship transit lanes to and from San Diego Bay traverse the nearshore area. Petroleum development in the nearshore area would encroach upon the military training areas and would jeopardize the safe transit of the military ships as they arrive and depart San Diego Bay. The introduction of offshore structures would compromise the Navy's ability to carry out its mission and would not be in the best interest of the nation. . -Discussion The Navy observers to the Task Force, on June 3, 1983, provided the following information regarding the military training areas off the San Diego Coast. (Refer to Figure 3.) These training areas provide support to half of the Pacific Fleet (120 ships and approximately 500 planes) hom-e-ported in San Diego and Long Beach. . Also, these are the only training areas for the specific fleet activities on the West Coast; the closest existing alternative training areas are located near Hawaii. 1. ' 2. 3. 4. 5. Simulated Low Level Bombing and Rocket Firing Training Range. This range is used six hours a day, 104 days per year. The range is used in conjunction with the amphibious assault training area at Camp Pendleton. . Amphibious Operations Area. This training area located off Camp Pendleton is used four hours a day, 260 days per year. This training area is used by the Navy and Marine Corps to maintain their readiness capability. Encinitas Naval Electronic Testing Area. This training area .is used by surface ships and submarines to test and calibrate the ships' navigation systems. The area is used six hours a day, 260 days per year. Point Loma Warfare Range. This training area is used by surface ships to test and calibrate the ships' warfare systems. This area is used 24 hours a day, 120 days per year. Fleet Anchorages and Amphibious Assault Training Areas. These areas located offshore the Silver Strand, the entrance to San Diego Bay, and Point Loma are used.24 hours a day, 260 days per year.. The amphibious assault training is used in conjunction with the area of Camp Pendleton and the oper- ations of the Amphibious Base located in the City of Coronado. 3 6. Submarine Training Area. This area is used 24 hours a day, 260 days per year. 7- - Submarine Transit Lanes. These lanes are used 24 hours a day, 360 days per year. The Navy's general concerns regarding OCS development are: 1. Exploration ships and drilling platforms are hazards to navigation which affect training exercises and electronic testing, because they force the ships to maneuver outside their training parameters. 2. Drilling noises significantly affect the underwater electronic testing systems. Relocation of the training areas would increase the transit time for the ships and reduce the training time. The training areas are conveniently located between the Long Beach and San Diego Harbors. The onshore support systems have been established over the years and a relocation of the areas would be a significant impact to the readiness capability of the fleet. - Lease Sale No. 48 Position. The tracts shown on the composite map (Figure 3) reflect those tracts the Navy recommended for deletion during Lease Sale No. 48. Because the use of the training areas have increased since 1979, the impact to the fleet would be greater if these or other tracts within the training area were offered in Lease Sale No. 80. - The DEIS states: "Impacts to military operations as a result of the proposed lease offering are expected to be high (significant alterations to military opertaions would be required). This is the result of the tremendous activity levels of both the military and oil industry overlapping as a result of the Proposal." (p. 2-36.) . Conclusion The conflict between military operations and offshore oil and gas development is significant and may not be reconciled without affecting military readiness. The DEIS recommends two stipulations that would allow shared use of the offshore military training areas. The stipulations would force the military to compromise its training activities and readiness for a very small resource. If OCS develop- ment is permitted to occur hi the nearshore area, that development could be used as a reason to relocate ships presently home-ported in San Diego, Such a reloca- tion would have a significant adverse impact to the region's economy. The Board's concern should not be modified. Air -- Quality Issue Statement The Board of Directors has adopted the 1982 State Implementation Plan to meet the national air quality standards as mandated by Congress. The implementation of the plan by the local governments and the business community will enable this region to meet the 1987 fedeTal ozone standards for loc2lly generated emissions. The introduction of petroleum development and its associated hydrocarbon emissions off the San Diego coast will preclude San Diego from attaining the San Diego would have no control over the development, jyd the adverse emissions would exacerbate the emission transit problem from the . congressional standard. os Angeles Au Basin, 4 Discussion Attachment 1 describes the types and amounts of air pollutants that are emitted . from exploratory and production drilling activities. The DEIS states that the air . quality impacts would be "low to moderate" (p. 2-34). The Department of the Interior air quality analysis is based upon a generic study for the entire California coast. The Offshore and Coastal Dispersion Model is being developed by the Department of the Interior to assess the effects of offshore emissions from point sources on air quality of coastal regions. This model is expected to be released this fall, and was not used in the Lease Sale No. 80 EIS analysis. The Air . Resources Board report entitled "Air Quality Aspects of the Development of Offshore Oil and Gas Activities" (February 1982) concludes that air quality emissions from OCS activities have a significant onshore impact. The County Air Pollution Control District has not made a determination as to what the impacts would be to the region if petroleum development should occur as proposed. Conclusion The effects on air quality from potential petroleum activities associated with the Lease Sale were estimated through computer simulated models. Site specific information was not used in the DEIS arialysis, and will not be available until development actually takes place. San Diego is a non-attainment area for ozone and the emissions associated with one exploratory drilling operation are equivalent to 5,000 1982 passenger cars traveling 50 miles per day for one year. The DEXS did not address the specific air quality impacts to the San Diego region. The Board's concern regarding air quality should not be modified. Regional Economic Impacts Issue Statement . 8 The regional economic strategy has been to emphasize the recreational and tourist sectors of the economy and to selectively diversify the industrial base. The San Deigo region has significant environmental assets and an essential part of the economic strategy is the enhancement of those assets while promoting economic development. The implications and potential consequences of nearshore oil and gas development 'are inconsistent with the regional economic strategy. Discussion The DEIS concludes on page 2-35 the following: "The expected impacts to recreation, tourism, sportfishing and visual resources as a result of the proposal are very low. Localized low impacts are expected to recr?ation, tourism, and sportfishing as a result of offshore platforms and onshore .facilities. Localized moder- ate impacts to visual r-&ources may occur if a platform is placed off the area from Pt. Conception to Montecito, off San Miguel or Anacapa Islands, off Palos Verdes, off the Lagunas, off La Jolla, off Sunset Cliffs or off Avalon. Overall the impacts for-the proposal are very . low." The primary source for the evaluation of recreational activity and allied resources for the DEE is a report entitled "Inventory and Evaluation of California Coastal 5 .. . Recreation and Aesthetic Resources" prepared by the Granville Corporation and published in 1981. At its February 5, 1982 meeting, the SANDAG Board trans- mitted the following comment to the Secretary of the Interior regarding this report: "The 'Inventory and Evaluation .of California Coastal Recreation and Aesthetic Resources' prepared by the Department of Interior under- estimates the economic values of the San Diego resources, and the methodology is incomplete because it evaluated only active recreation participation and not the passive value of resources. Because of these deficiencies, the Department of Interior should not rely solely on the conclusions of the report to determine whether or not OCS onshore and offshore facilities are compatible in the San Diego region. Prior to any decision to lease offshore San Diego, the Department should con- sult with the local government and fully consider the local value placed on these resources." The DEIS, on page 2-50, estimates a recreational dollar value of over $122 million in 1980. Information updated from a report prepared by Arthur D. Little, Inc. entitled "Tourism in San Diego: Its Economic, Fiscal, and Environmental Impacts" (May 1974) indicates that 1982 recreational dollars associated with saltwater bathing, boating and fishing is approximately $323 million. Conclusion - The DEIS understates and underestimates the impacts of petroleum development to the recreation and tourism industry. The Board's concern should not be modified. Marine Mammals and Seabirds Issue Statement One of the unique coastal resources in the San Diego region is the marine mammals and seabirds. The marine environment and its inhabitants are fragile and easily affected by man-induced activities. Several sectors of San Diego's recreation and tourist industry are related to the marine environment. The impacts and consequences of petroleum development in the marine environment to the mammals and seabirds is unknown. _.. ~ .. Discussion Information presented to the Task Force reveals that scientific research related to marine animals and seabirds and the long-term effects of petroleum develop- ment is inconclusive and more research is required. In its draft Environmental Studies Plan for Fiscal Year 1985, the Department of the Interior lists several studies related to this subject that will not be completed prior to 1985 and still other research efforts that won't be completed until 1987 or later. -I__ Conclusion . -- Because scientific research is not yet completed regarding marine mammals and - seabirds, the Board should continue to support research into the effects of petroleurn development to the marine environment. .6 Local Energy Supplies and Cons'ervation The'performance of the region between 1980 and 1982 in development of local energy supplies (including conservation and alternative enerw projects) is: ,, c Electricity. KwH per year saved, the equivalent of 908,000 bbls. of oil. Per capita consumption has decreased. 7%, resulting in 550 million Natural Gas. Per capital consumption has decreased 9%, resulting in savings of 51 million therms per year, the equivalent of 930,000 bbls. of oil. . .' Motor Vehicle Fuel. Per capita consumption has decreased 9%, resulting in savings of 89 million gzllons per year, the equivalent of 2,020,000 bbls. of oil. Total Annual Savings. Eight percent (8%) energy savings for all fuels, or 3.9 million bbls. of oil per year. Over a ten-year period, the minimum life of conservation and alternative energy equipment, the savings would be 39 million bbls. of oil. This 8% decrease in consumption has occurred in the .face of a 5% increase lover 90,000 people) in the region's population during the 1980-1982 piriod. The Gross Regional Product estimated by the San Diego Economic Research Bureau did not change significantly in these two years. The decrease in consumption reflects the response of energy consumers to energy price increases in the 1970's which have continued into the 80's. Real natural gas prices (subtracting the effects of general inflation) increased 33% between 1980 and 1892. Real electricity .prices increased 25%. While statewide travel per capita increased in response to lower gasoline prices, consumers continued to purchase more fuel-efficient new cars which resulted in a net reduction in gasoline consump tion. This reduction in per capita and actual energy consumption in the region is part of a long-term trend identified by SANDAG. The Regional Energy Plan Update was adopted by the SANDAG Board of Directors in 1982. The Plan sets forth a strategy by which the region can increase energy supply reliability, reduce the rate of energy cost increases, and strengthen the local economy by developing locd energy supplies. These local energy supplies include: (1) conservation and energy efficient equipment in homes, businesses, industries and public institutions and power production through renewa$le resources such as solar, wind, hydro; and (2) efficient production techniques and new fuel sources, such as cogeneration and solid waste. Real gasoline prices decreased 14%. These technologies can decrease this region's need for conventional fuels. The Regional Energy Plan. Update forecasts potential 1990 annual electricity savings of 17%, natural gas savings s?f 40% and vehicle fuel savings of 43% due to the use of more efficient and renewable energy technologies. The 8% decrease in regional consumption in the 1980-82 period reflects major local investments in these technologies, which will reduce the need to purchase non-local energy supplies in the future. . . 8 San Diego. ASSOCIATION OF GOVERNMENTS 9' FIGURE 2 San Diego ASSOCIATION OF GOVERNMENTS MILITARY OPERATING AREAS PT. LOMA UNDERWATER ELECTRONIC H LEASE SALE NO. 48 TRACT DELETIONS pJ to MEASUREMENT RANGE . .. ~ * 30 25 10 ' 15 10 J F l- MILLS . 10 ATTACHMENT 1 AIR QUALITY EMISSIONS FROM THE DEVELOPMENT OF OFFSHORE OIL AND GAS RESOURCES ,, % - The air quality impacts of offshore oil and gas development is a great concern to the local elected officials and residents of the San Diego region. The following excerpt is from a State of California Air Resources Board report and it describes the type and amount of major air pollutants emitted from exploratory and produc- tion drilling activities. TYPES AND AMOUNT OF AIR POLLUTANTS1' The major air pollutants emitted from exploratory drilling activities are: (a) oxides of nitrogen (NOx), (b) volatile organic compounds (VOCs or hydrocarbons), (c) particulate matter (PM or TSP), (d) oxides 'of sulfur (SOX), and (e) carbon monoxide (CO). . These pollutants are released by: . 1. The diesel engines onboard drillships (these engines supply power for well drilling and drillship movements), Flaring of gas (if discovered). 2. Support vessel engines, and 3. TABLE 1 SUMMARY OF DRILLING EMISSIONS FROM ONE DRSLLSHIP~ NOx - vocs PM - sox - co - ' Emissions in pounds/hour 73 9 3.4 4 12 Emissions in pounds/day 1,752 21 6 82 96 28 8 80 10 4 4 13 319 40 15 17 .52 3 Emissions in tons/welI Emissions in tons/year Source: Hooks, McCloskey and Associates (1981). Source: Air Quality Aspects of the Development of Offshore Oil and Gas Activities, State of California Air Resoucces Board, pp. 45-59, February 25, 1982. Average emissions for drilling and testing a well assuming drilling requires 68 days per well and testing requires 23 days per well. Assumes 4 wells per year and 91 days to drill and test each well. .. . The following is a brief discussion of the types And amount of air pollutants emitted from the above sources. Re'ferences will'be made to Table 1. Table 1 lists the five regulated pollutants emitted from Exxon's drilling activities and the emission rate for each pollutant. . 1. Oxides of Nitrogen (NOx) ' Oxides of nitrogen are emitted'from the large diesel engines used to generate power onboard the drillship. Most of the NOx is emitted as NO (nitric oxide), wliich is formed by the high temperature reaction between the nitrogen and oxygen in the combustion air. In the presence of sunlight oxides of nitrogen and VOCs are the primary pollutants necessary for the formation of oxidant (ozone). 2. As seen in Table 1, drillships emit large amounts of NOx. A drillship will produce an average of 73 pounds of NOx per hour during drilling. The total NOx emitted from a drillship during the drilling of one well (approximately 90 days) is estimated to be about 80 tons. During certain phases of the drilling operation such as combined drilling and drillship positianing, the NOx emission rate can be twice this value. Based on maximum energy usage during the drillin& cycle, the NOx emission rate may be as great as 150 pounds per hour. Volatile Organic Compounds (VOCs) VOCx from drilling operations generally result from incomplete fuel combustion, evaporative emissions, and fugitive emissions from fuel storage equipment, pumps, and flanges. As indicated previously, VOCs and NOx in the presence of sunlight, are primary pollutants in the formation of oxidant (ozone). As shown in Table 1, the average VOC emissions during drilling are estimated to be 9 pounds per hour or 10 tons per well. 3. Particulate Matter (PM) Particulate matter, which is emitted from the diesel engines on board a drillship, results from the incomplete fuel combustion and fuel contaminants. The average PM emissions during drilling are estimated to be 3.4 pounds per hour or 4 tons per well. 4. Oxides of Sulfur (SOX) In diesel engines, sulfur is a fuel contaminant which is oxidized (combusted) to form mainly sulfur dioxide (SOz). The average estimated SOX emissions during drilling are 4 pounds per hour and 4 tons per well based on a fuel sulfur content of 0.2%. " 5. Carbon Monoxide (CO) c . CO is a product of incomplete fuel combustion. The average estimated CO emissions during drilling are 12 pounds per hour and 13 tons per well. . The emissions presented above are for a single drillship and do not include emissions from support vessels, drillship movement, or the flaring of high sulfur content natural gas. Support vessels are used to transport crew and materials to and from the drillship. Support vessels usually consist of crew and supply boats and helicopters. The amount of pollutants emitted by these vessels is dependent on the distance the drillship is from shore and the number of trips which are required. Table 2 presents an estimate of emissions from support vessels assuming a round trip distance of 120 miles for the crew and supply boats and 50 miles for helicopters. TABLE 2 SUPPORT VESSEL EMXSSIONS FOR THE DRILLING OF ONE WELL co - sox - PM - NOx VOCs a- - Emissions in tons per well 10 2 1 1 4 Source: Hooks, McCloskey and Associates (1981). I Emissions from drillship movement are dependent on the type of drillship and the distance that the drillship must.trave1. Table 3 p esents Chevron estimates of the emissions associated witk a drillship relocation requiring 18 hours. TABLE 3 DRLLSHIP RELOCATION EMISSIONS co - sox - PM - NOx 'VOCs -- Emissions (tons per relocation4) 1.1 0.1 0.1 0.1 0.2 Source: Chevron USA, Inc. (1981). Flaring of natural gas may emit substantial amounts of SO2 if the sulfur content of the gas is high. For example, if 1.5 million cubic feet of natural gas containing 1% hydrogen sulfide (H2S) is flared, SO2 emissions would exceed one ton. However, it is difficult to predict SO2 emissions from flaring due to uncertainties about the quantity of natural gas which will be flared and the sulfur content of that gas. Exploration drilling emissions can be compared to other emission sources such as emissions from motor vehicles and to emissions from an OCS production platform such as Chevron's Platform Grace (now operating on the OCS for oil and gas production). * Assumes 18 hours per relocation. Table 4 is a comparison of the number of 1982 passenger carsI each traveling 50 miles per day, which would generate the same amourit of oxides of nitrogen (NOx), volatile organic conpounds (VOCs), and carbon monoxide (CO) as a single drilling operation for one year. Since passenger cars emit very little PM or SO29 an analysis for these pollutants is not included. I. c TABLE 4 COMPARISON OF OCS EXPLORATORY EMISSIONS WITH PASSENGER CAR EMISSIONS co - - NOx vocs One drilling ope ation produces in tons per year Number of 1982 passenger cars equivalent to one drilling operation 23,000 5,000 370 3 1.9 . 40 52 5 The drilling operation chosen for this comparison is one which has recently received all approvals, and should be typical of most such operations. Emissions for the drilling operation are based on information supplied by Exxon and Chevron. PRODUCTION PLATFORMS If substantial reserves of oil or gas are delineated by exploratory drilling, a fixed production platform is usually established. Offshore platforms are large metal structures which are placed in water 50 to 1,000 feet deep and are attached to the ocean floor by rigid steel legs. For shallow waters, artificial islands have sometimes been used instead of platforms. A "typical" 6 platform has the following types of equipment: 1. 2. Drilling, 3. Gasprocessing, ' 4. Oil processing, and 5. Water treatment. Power generating and fuel storage, Power generating equipment is needed to supply ele'ctric power for drilling, pro- cessing, and pumping. Power is usually supplied by gas turbines, while emergency power is supplied by diesel engines. Some platforms use supplied electrical power supplied from onshore generating equipment through underwater electrical cables. -. From Table 1. . .' discussion is very general. It is difficult to characterize a "typical" offshore platform, therefore, this Well drilling equipment used on a platform is identical to that used on a drillship. Platforms are designed so that 20 to 90 wells may be drilled either by directional or angular drilling. This allows a single platform to drill a network of wells extending over several thousand acres. Gas processing equipment on R platform usually consists of gas compressors and dehydrators. Gas compressors are used to raise the gas pressure from a few atmospheres pressure to 20 or more atmospheres. If a platform does not pipe the gas to shore, the gas is usually compressed and reinjected into the field to maintain the natural reservoir pressure and thereby maximize oil production. In addition, a portion of the gas is generally used as fuel for the gas turbines and other combustion equipment used to generate electricity and process heat, respectively. When production is initiated, the gas cannot be reinjected or pro- cessed. In such event, the gas will be flared. Gas dehydrators are used to remove water from the gas. Most dehydrators use tri-ethylene glycol as a dehydrating agent. Gas containing water vapor is passed through a desorber where it comes in direct contact with glycol, which absorbs the water from the gas. The glycol is then sent to a reboiler where the water is removed, and the glycol is then returned to the desorber. If significant quantities of hydrogen sulfide (HzS) are present in the gas, the HZS can be removed by treatment at the platform prior to use as fuel or being sent onshore. Oil processing equipment used on a platform includes separators, heaters, treaters, and pumps. Separators are used to separate the gas, oil and water fractions of the well fluid. Separators remove about 75% of the water from the oil.. The remaining 25% is emulsified in the oil, and heater treaters or chemical- electric units are needed. to break up the oil/w'ater emulsion, prior to transporting the oil by either pipeline or tanker. Pumps are used to raise the oil (actually a mixture of gas, oil and water) from the field, and to pump it onshore or into an oil tanker. Water treating equipment includes oil/water separators and froth flotation units. This equipment is desinged to recapture any residual hydrocarbons in the water. After treatment, the water is often reinjected into the field to maintain reservoir pressure. . TYPES AND AMOUNTS OF AIR POLLUTANTS - The major air pollutants emitted from offshore platforms are NOx, VOCs, PM, so2 and CO. The major source of NOx, PM and CO is combustion emissions from power generating equipment. If high sulfur content gas is discovered, flaring this gas can be a major source of SOz. VOCs are emitted from the glycol regenerator, heater treaters, water treatment equipment, pump seals, and various precess and storage vents, All five of the above-listed pollutants are emitted from fugitive sources or as a result of incomplete combustion (e.g., flaring). Table 6 summarizes the estimated total emissions of air pollutants from OCS As seen in Table 6, the ' platforms currently operating off the California coast. .. .- predominant pollutant emitted from offshore platforms in the Santa Barbara Channel is NOx (466 tons per year). .For comparison, the total annual NQx emissions for 1876 from stationary and mobile sources (excluding OCS emission) in San Luis Obispo, Santa Barbara and Ventura Counties were 75,000 tons per year. Even though the magnitude of the emission estimates presented in Table 6 is quite large, these estimates do not include emissions from support vessels, which collectively are substantial. Yearly emissions from crew and work boats serving Union's platforms A, B and C have been estimated to be 14 tons of NOx, 3 tons of CO, 1 ton each of SO2 and PM, and 0.5 tons of reactive VOCs. TABLE 6 Platform A (Union) B (Union) C (Union) Henry (Sun) Hillhouse (sun19 ' Houchin (Phillip Hogm (Phillips) ' Hondo (Exxon) OS&T (Exxon) Habitat Grace (Chevron Gilda (Chevron) Gina (Union) l3 San Pedro Bay OCS PLATFORM EMISSIONS r - Emjssions (tons per year)7 co - sox - PM - NOx VOCsO CI 9.1 0.1 0.7 0.04 3.4 8.9 . 0.1 0.6 0.02 3.4 0.32 0.02 0.03 0.02 .0.07 58.7 2.2 4.3 1.9 17.9 - 31.3 114.0 36.0 166 0.5 41.1 363 - 8.4 13.9 2.3 6 0.5 0.4 a49 - 1.8 0.2 2.5 11 0.2 1.3 18 - - 0.4 21.5 82.1 20.8 2.6 7.8 60 - 2.4 0.5 44.2 9.4 37 - ' TOTAL: 829 118 41 23 1 85 Does not include support vessels or tanker emissions. Reactive YOCs. Power supplied by Henry. lo Power cable from shore. '1 Onshore mitigation supplied. l2 Assumes no drilling activities. l3 Total VOCs, reactive not available. Source: Chamber Consultants and Planners, DEIR for Texaco Platform Habitat; Dames and Moore, EIR for Union Platforms Gina and Gilda; Permit Conditions for Chevron's Carpinteria Facility (Platform Grace); Permit Conditions for Shell Beta Project; Dames and Moore, EIR far Exxon's Hondo Field (as revised by Memorandum of Agreement.