UGS PG&E 032024-01

Summary

SCH Number
2024050376
Public Agency
California Department of Conservation (DOC)
Document Title
UGS PG&E 032024-01
Document Type
NOE - Notice of Exemption
Received
Posted
5/9/2024
Document Description
Project Description: Pacific Gas and Electric Company (PG&E) submitted four Notice of Intentions (NOI) to rework existing underground gas storage (UGS) wells at the McDonald Island Natural Gas Storage Facility (McDonald Island Facility) in San Joaquin County (Project). The wells that will be reworked are part of the McDonald Island Facility, an existing facility of an investor-owned utility that is used to provide natural gas services. The McDonald Island Facility is on the man-made McDonald Island, in the Sacramento-San Joaquin Delta, in San Joaquin County; approximately 40 miles south of Sacramento and 10 miles west of Stockton. McDonald Island is 5,900 acres in size and bounded on the north by San Joaquin River, on the west by Middle River and Latham Slough, and on the south by Empire Cut. The McDonald Island Facility on the island is approximately 2,760 acres. The remaining acreage is actively farmed. The McDonald Island Facility is currently comprised of 88 wells: 69 active gas storage wells, 2 idle gas storage wells, 5 abandoned gas storage wells, 4 out of service gas storage wells, 7 active observation wells, and 1 idle observation well. The purpose is to rework an underground gas storage (UGS) well. Activity includes retrieve existing tubing string and packer; retrieve production liner; perform casing integrity wireline surveys; replace existing wellhead; install new production liner and gravel pack; and install new tubing string and packer to enhance the safety of UGS projects. This action is in compliance with revised regulations (14 CCR § 1726 et seq.) to enhance the safety of UGS projects. In 2018, CalGEM promulgated regulations that establish standards for the design, construction, and maintenance of all gas storage wells. The regulations include stringent well construction standards that are required to ensure that gas storage wells are safe and will maintain their integrity over time. The well construction standards promote environmental safety by focusing on leak prevention. The proposed project consists of CalGEM approving four permits for PG&E to perform rework on the gas wells listed below, in the McDonald Island Gas Field. API# 0407720535, Whiskey Slough 20-W API# 0407720192, Whiskey Slough 6-W API# 0407720216, Turner Cut 3-S API# 0407720219, Turner Cut 2-S

Contact Information

Name
Jan Perez
Agency Name
Department of Conservation, Geologic Energy Management Division
Job Title
Senior Environmental Scientist
Contact Types
Lead/Public Agency

Location

Counties
San Joaquin
Regions
Northern California
Township
02N
Range
04E
Section
25
Base
NAD83

Notice of Exemption

Exempt Status
Categorical Exemption
Type, Section or Code
14 CCR § 15301
Reasons for Exemption
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…” These reworks involve the installation of CalGEM compliant tubing and packer replacement. Once the work is completed the well will be returned to service. The installation of CalGEM compliant tubing and packer replacement will maintain or diminish the throughput capacity of the reworked gas storage well. Therefore, there is only negligible or no expansion of the existing use. The proposed Project is considered remedial because it is attendant to compliance with updated CalGEM regulations.

Exempt Status
Categorical Exemption
Type, Section or Code
14 CCR §15302
Reasons for Exemption
Class 2, Replacement or Reconstruction (14 CCR §15302): Class 2 applies because it consists of “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 substantially the same purpose and capacity as the structure replaced[.]” Examples of Class 2 include, but are not limited to, “Replacement or reconstruction of existing utility systems and/or facilities involving negligible or no expansion of capacity.” The proposed project involves installation of CalGEM compliant tubing and packer replacement, replacement of existing wellhead; install new production liner and gravel pack; and install new tubing string and packer, to enhance the safety of UGS projects. The location of the well will not change, nor will the underground structure of the well (the wellbore). The reworked well will serve the same purpose as other UGS wells, a gas storage well, and continue to provide the same measure of deliverability or capacity.

Exempt Status
Categorical Exemption
Type, Section or Code
14 CCR § 15304
Reasons for Exemption
Class 4, Minor Alterations to Land (14 CCR §§ 15304, 1684.2): Class 4 exemption applies. The proposed 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 proposed project would not disturb any undisturbed areas. The proposed Project is located within an industrial area. Therefore, the proposed 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 reworks would not expand the facility and are conducted in order to comply with CalGEM safety regulations (remedial) and maintain level of service.

Exempt Status
Categorical Exemption
Type, Section or Code
14 CCR §§ 15307, 15308
Reasons for Exemption
Classes 7 and 8, Protection of Natural Resources and the Environment (14 CCR §§ 15307, 15308): Class 7 and Class 8 exemptions apply. The exemptions are for 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, the reworks involve the installation of CalGEM compliant tubing and packer and is attendant to compliance with the regulations CalGEM promulgated in 2018, that establish standards for the design, construction, and maintenance of all gas storage wells. The regulations include stringent well construction standards that decrease the risk for adverse impacts to natural resources in the area. CalGEM has statutory and regulatory authority to protect natural resources and the environment. The rework of these wells to install CalGEM compliant tubing and packer replacement will ensure that potential impacts to natural resources and the environment from compliance issues associated with the well are minimized, and the approval for the reworks 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, the reworks would assure the maintenance, restoration, enhancement, and/or protection of a natural resource and the environment.

Attachments

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