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Comment 3 for Open Comment for the June 22, 2023 Board Meeting (june2023opencomm) - Non-Reg.

First NameChris
Last NameGilbert
Email Addresschris@gilbertbiz.com
Affiliation
Subjectre: Item 23-6-2 methane leakage and repair
Comment
Thank you for addressing the issue of methane leakage and repair. 
Please consider these points in forming your policy.

•	There should be requirements or standards for notifying community
members of the details and response plan when leaks are found near
sensitive receptors like parks, schools, homes, hospitals, and
other community areas.
•	In addition to methane, CARB should include requirements for
testing for co-pollutants like BTEX compounds and VOCs when leaks
are found within 3,200 ft of communities, schools and other
sensitive receptors.
•	CARB should consider requirements for leak detection and repair
(LDAR) inspections to be increased at sites within 3,200 ft of
sensitive receptors such as communities  & schools.
•	The exemption of heavy crude oil (API gravity less than 20) from
LDAR requirements should be removed.
•	CARB should explore remote sensing methods other than by
satellite to identify leaks, such as airplane flyovers, drones, or
car-mounted detectors.
•	The updated regulation should not exempt separator and tank
systems that receive an average of less than 50 barrels of crude
oil or and condensate per day.
•	Records should be reported monthly with production figures or
requested monthly by CARB to ensure testing is being performed.

Attachment
Original File Name
Date and Time Comment Was Submitted 2023-06-22 11:19:56

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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