Patriot 112023-001

2024050341

California Department of Conservation (DOC)

NOE - Notice of Exemption

5/8/2024

5/8/2024

Nicole Trezza

Department of Conservation, Geologic Energy Management Division

Environmental Scientist

Lead/Public Agency

715 P Street, MS 1803
Sacramento, CA 95814

(916) 445-9686

CEQA@conservation.ca.gov

34°22'59.1"N 118°43'36.1"W

04N

18W

36

SB

Categorical Exemption

Class 1: California Code of Regulations, title 14, section 15301

Class 1, Existing Facilities (14 CCR §§ 15301, 1684.1): Class 1 exemption applies as CalGEM’s regulations state: “Class 1 consists of the operation, repair, maintenance, or minor alteration of existing public or private structures, facilities, mechanical equipment, or topographical features involving negligible or no expansion of use beyond that existing previously. The Class includes, but is not limited to: remedial, maintenance, conversion, and abandonment work on oil, gas, injection, and geothermal wells…”. This rework is a cement squeeze for casing repair and is considered repair and maintenance of the well in order to ensure O&G production. The well will remain a production well with the same capacity. This rework does not propose any changes to the wellbore or structure of the well. Accordingly, there is no expansion of use beyond that previously existing.

Categorical Exemption

Class 2: California Code of Regulations, title 14, section 15302

Class 2, Replacement or Reconstruction (14 CCR § 15302): It is also a potential Class 2 as rework of the well could be considered “replacement or reconstruction of existing structures and facilities where the new structure will be located on the same site as the structure replaced and will have the same purpose and capacity.” This is a rework that involves repairing or reconstructing failed casing of an existing production well through a cement squeeze job followed by a casing pressure test to verify the repair and does not propose changes to the structure of the well (the wellbore). The location of the well will not change, nor will the underground structure of the well (the wellbore) change, nor will the purpose of the well, which is production. After the rework, the well will have the same capacity.

Categorical Exemption

Class 4: California Code of Regulations, title 14, section 15304

Class 4, Minor Alterations to Land (14 CCR §§ 15304, 1684.2): It is also a possible Class 4. The project would be conducted entirely on an existing pad with enough space to contain all equipment. The project would not disturb any undisturbed areas. The project is located within an industrial area. Therefore, the project “consists of drilling operations that result in only minor alterations with negligible or no permanent effects to the existing condition of the land, water, air, and/or vegetation.” The rework would not expand the facility and is conducted in order to maintain level of service.

Categorical Exemption

Classes 7 and 8: California Code of Regulations, title 14, sections 15307, 15308

Classes 7 and 8, Protection of Natural Resources and the Environment (14 CCR §§ 15307, 15308): It is also a possible Class 7 and Class 8, which includes actions taken by regulatory agencies as authorized by law to assure the maintenance, restoration, enhancement, or protection of a natural resource or the environment where the regulatory process involves procedures for the protection of the environment.” As demonstrated in the record, this O&G well presents a safety concern that may increase the risk for adverse impacts to the environment or natural resources in the area. CalGEM has statutory and regulatory authority to protect natural resources and the environment. Rework of this well would ensure that potential impacts to natural resources and the environment from compliance issues associated with the well are minimized, and the approval for the rework will also include conditions that protect natural resources and the environment. Therefore, as demonstrated in the proposed project file description of the well rework operations, which include locating the hole in the casing, a cement squeeze job, and a casing pressure test to verify the repair, the rework would assure the maintenance, restoration, enhancement, and/or protection of a natural resource and the environment.