First Name | Chris |
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Last Name | Gilbert |
Email Address | chris@gilbertbiz.com |
Affiliation | |
Subject | re: 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. |
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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.