APPROVED. PXP 2009 Tank Leak Detection and Containment at Inglewood Oil Field. Baldwin Hills CSD Conditions L.18. and E.29.e.

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1 PXP 2009 Tank Leak Detection and Containment at Inglewood Oil Field Baldwin Hills CSD Conditions L.18. and E.29.e. WORKING DRAFT SUBJECT TO CHANGE BASED ON COUNTY REVIEW AND ACCEPTANCE Prepared for: May 2009 Prepared by: Plains Exploration & Production Co. Arup 5640 South Fairfax Avenue West Jefferson Boulevard Los Angeles, CA Suite 200 Los Angeles, CA 90066

2 Contents Contents i Tables i Appendices i 1 Introduction Operations Overview CSD Requirements 1 2 Code Requirements Applicable Codes Code Review DOGGR Code Requirements Tank Leak Detection Overview Tank Locations, Sizes, Contents, and Containment Locations Tank Leak Detection Procedures 6 3 Conclusion 7 Appendix A 8 Tables Figure 1 Tank Secondary Containment Type 5 Appendices Appendix A 8 Page i / 8 Final May 2009

3 1 Introduction Plains Exploration & Production Company (PXP) operates the Inglewood Oil Field in the Baldwin Hills zoned District of Los Angeles County. The Inglewood Oil Field, which covers approximately 1,000 acres, is surrounded by single and multiple family dwellings as well as recreational, institutional, commercial, and industrial uses. To address issues of land use compatibility with surrounding land uses, the (CSD) was adopted by the Los Angeles Planning Department on October 28, The goal of the CSD is to provide a means of implementing regulations, safeguards, and controls for activities related to drilling for and producing oil and gas within the Inglewood Oil Field. 1.1 Operations Overview At the Baldwin Hills location, PXP is drilling for sweet crude oil. Sweet crude oil is a type of petroleum which has low sulfur content. Two types of wells are drilled in the oil field; injection and production wells. Injection wells are used to pump fluids into the oil bearing geologic formation at depth, forcing the oily water in the formation to migrate to nearby production wells for recovery. Liquid storage tanks are utilized at various stages of the production process. Produced water (brine) is re-injected from holding tanks by pumping it via injection wells into the oil bearing strata to push the oil towards production wells where this produced water is then extracted with the accompanying oil fraction and placed into tanks for separation of the oil, gas, and water. This produced water is stored for reinjection and the cycle starts over. There are also tanks used for oil storage prior to sales located at the site. The tanks referenced above are defined in the Tank Location Table below and locations illustrated as per the Base Map in Appendix A at the end of this report. 1.2 CSD Requirements CSD Section L.18 requires that a program for detecting and dealing with tank bottom leaks be submitted to the fire chief. Page 1 / 8 Final May 2009

4 Within 180 days following the effective date, or at such later date as may be approved by the fire chief for good cause shown, the operator shall develop and submit to the fire chief, for review and approval, a program for detecting and dealing with tank bottom leaks, as required by subsection E.29.e. The operator shall take such actions as may be necessary for the program to be approved by the fire chief. CSD Section E.29.e speaks directly to requirements addressing tank bottom leaks. The operator shall design, implement, and comply with a program, approved by the fire chief, for controlling and detecting tank bottom leaks on all tanks at the oil field. The operator may use a combination of methods including but not limited to diversion walls, dikes, tank foundations of concrete or gravel, and a tank bottom leak detection system in compliance with Title 14 of the California Code and Regulations section 1773, or subsequently enacted state regulation regarding tank bottom leaks. Page 2 / 8 Final May 2009

5 2 Code Requirements The section of the report identifies the codes, standard and guidelines for the project and the compliance status relating to the operations at the Baldwin Hills Oil Field. 2.1 Applicable Codes The following codes, standards and guidelines provide requirements applicable to the project and have been reviewed with regard to tank bottom leak detectionrelated requirements: Title 14 California Code Requirements, Department of Oil, Gas, and Geothermal Resources (DOGGR) 1773 Tank Settings 2.2 Code Review The following section identifies the code requirements applicable to the oil field operations and the compliance status or recommendations to corrective action DOGGR Code Requirements The DOGGR code requirements for tank settings are shown below Tank Settings. Tank settings in areas where damage to life, health, property, or natural resources might occur as a result of leakage, shall have a method for control of the spilled fluid and detection of tank-bottom leaks. This may be accomplished by employing a combination of the following containment and detection methods: (a) For containment: (1) A drainage system for safe fluid containment (2) Diversion walls to direct fluids to a preferred collection point. (3) Dikes or fire walls capable of containing the volume of the largest (b) For leak detection: tank. Tank settings in urban areas shall have dikes. (1) A tank installation that allows the exterior surface, including the bottom of the tank and connection piping, to be monitored by direct viewing. (2) A tank foundation of concrete or gravel. (3) A tank bottom leak detection system. NOTE: Authority cited: Section 3013, Public Resources Code. Reference: Section 3106, Public Resources Code. Page 3 / 8 Final May 2009

6 . 2.3 Tank Leak Detection Overview As part of our ongoing efforts to ensure safe and environmentally friendly operations, and to satisfy DOGGR and CSD requirements, visual inspections for detection of tank bottom leaks are performed at regular intervals by field operations personnel. The ongoing visual inspections ensure quick repairs are made to mitigate any potential environmental impact. 2.4 Tank Locations, Sizes, Contents, and Containment Locations All tank secondary containment complies with DOGGR requirements as per the CSD. Throughout the site these requirements are met in the following manner. In general, tanks that may contain crude oil and produced water requiring secondary containment have foundations of concrete or gravel. Secondary containment for these tanks is accomplished by a combination of concrete or concrete block retaining walls, dikes and berms. The volume of available secondary containment is capable of containing volumes in excess of the full volume of each tank. Page 4 / 8 Final May 2009

7 Tank # Name/Type Capacity (bbls) Containment Type (berm, concrete wall, etc.) 1 Stocker Wash Tank #1 10,000 wall 2 Stocker Wash Tank #2 10,000 wall 3 Inglewood Stock Tank #1 5,000 berm 4 Run-Off Tank (proposed) 5,000 berm 5 Lease Run-off Tanks (to be removed) 500 n/a 6 Lease Run-off Tanks (to be removed) 500 n/a 7 Waste Water Tank #1 1,000 berm 8 Waste Water Tank #2 1,000 berm 9 Fresh Water Tank 3,000 none 10 Inglewood Wash Tank #2 10,000 berm 11 Inglewood Wash Tank #3 10,000 berm 12 BC Stock Tank #1 3,000 berm 13 Inglewood Stock Tank #2 3,000 berm 14 Inglewood Stock Tank #3 1,000 berm 15 BC Wash Tank 5,000 berm 16 Inglewood Wash Tank #4 10,000 berm 17 Johnson Produced Water 10,000 berm 18 LAI Produced Water Spill-Over 2,400 berm 19 Slop Tank 500 berm 20 LAI Wash Tank 10,000 berm 21 T-1 Wash Tank 10,000 berm 22 Raw Tank T-1A 5,000 wall / berm 23 Raw Tank T-1B 5,000 wall / berm 24 Raw Tank T-3 5,000 berm 25 Raw Tank T-5 5,000 berm 26 Raw Tank T-6 5,000 berm 27 Processed Water 5,000 berm 28 Surge Tanks 1,000 berm 29 Surge Tanks 1,000 berm 30 Packard Stock Tank #1 5,000 wall / berm 31 Packard Stock Tank #1 - PXP Sales 5,000 wall / berm 32 Packard Stock Tank #1 - Spare 5,000 wall / berm 33 Vickers 1 Fresh Water - city water 5,000 none 34 T-Vic Pre-Wemco 3,000 wall 35 T-Vic Produced Water 5,000 wall / berm 36 T-Vic Emulsion 3,000 wall / berm 37 T-Vic Rain Run-off 500 wall 38 Vickers 2 Stock Tank 3,000 wall / berm Figure 1 Tank Secondary Containment Type Page 5 / 8 Final May 2009

8 2.5 Tank Leak Detection Procedures The following provides the procedures PXP utilizes to detect tank leaks: Each tank shall be assessed daily. Assessment shall be conducted by field operations personnel. Inspection of each tank consists of a visual inspection of the sides and base of the tank, including valves, fittings, and piping connecting to the tank. Personnel shall visually inspect the area around the perimeter of each tank, as this is where signs of tank bottom leaks will first appear. Any tank contents discovered on the sides of the tanks or at the base will require immediate action from the field operations personnel. Although the visual inspection is primarily for bottom leak detection, any leak requiring action shall be addressed in an appropriate manner. This includes valves, fittings, piping, etc. Page 6 / 8 Final May 2009

9 3 Conclusion PXP addresses the CSD requirements for controlling and detecting tank bottom leaks through DOGGR-approved strategies for containment and for leak detection. PXP conducts daily visual inspections for tank leaks, and has provided both an inventory and location map of tanks at the Inglewood site. Page 7 / 8 Final May 2009

10 Appendix A Page 8 / 8 Final May 2009

APPROVED. PXP 2009 Community Alert Notification (CAN) System. Baldwin Hills CSD Conditions E.1.a & L.1.b. March 2009

APPROVED. PXP 2009 Community Alert Notification (CAN) System. Baldwin Hills CSD Conditions E.1.a & L.1.b. March 2009 PXP 2009 Community Alert Notification (CAN) System Baldwin Hills CSD Conditions E.1.a & L.1.b Prepared for: March 2009 Prepared by: Plains Exploration & Production Co. Arup 5640 South Fairfax Avenue 12777