UGS PG&E 122023-004
Summary
SCH Number
2024050788
Public Agency
California Department of Conservation
(DOC)
Document Title
UGS PG&E 122023-004
Document Type
NOE - Notice of Exemption
Received
Posted
5/17/2024
Document Description
Pacific Gas and Electric Company (PG&E) submitted three Notice of Intention (NOIs) to rework two existing underground gas storage (UGS) and one existing observation well at the Los Medanos Natural Gas Storage Facility (Los Medanos Facility) in Contra Costa County (Project).
The wells that will be reworked are part of the Los Medanos Facility, an existing facility of an investor-owned utility that is used to provide natural gas services. Los Medanos Facility has a total of 22 wells and a maximum capacity of 17.9 billion cubic feet. The Los Medanos Facility is in Contra Costa County; approximately 6 miles east of the City of Martinez and 7 miles west of the City of Pittsburg.
The purpose of the proposed Project is to rework three wells which involves retrieving existing tubing string and packer; retrieving production liner; performing casing integrity wireline surveys; replacing existing wellhead; installing new production liner and gravel pack; and installation of new CalGEM compliant tubing string and packer. Once the work is completed the wells will be returned to service. This action is done to maintain the mechanical integrity of the wells and 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 three permits for PG&E to perform rework on the gas wells listed below, in the Los Medanos Gas Field.
API # 0401320144 Well Name: Los Medanos 5-B
API # 0401320299 Well Name: Los Medanos 13-C
API # 0401300135 Well Name: Ginochio 3-7
Contact Information
Name
Jan Perez
Agency Name
Department of Conservation, Geologic Energy Management Division
Job Title
Senior Environmental Scientist
Contact Types
Lead/Public Agency
Phone
Location
Coordinates
Counties
Contra Costa
Regions
San Francisco Bay Area
Township
02N
Range
01W
Section
18
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 retrieving existing tubing string and packer; retrieving production liner; performing casing integrity wireline surveys; replacing existing wellhead; installing new production liner and gravel pack; and installation of new CalGEM compliant tubing string and packer. Once the work is completed the wells 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 wells. 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.” These reworks involve retrieving existing tubing string and packer; retrieving production liner; performing casing integrity wireline surveys; replacing existing wellhead; installing new production liner and gravel pack; and installation of new CalGEM compliant tubing string and packer, to enhance the safety of UGS projects. The location of the wells will not change, nor will the underground structure of the wells (the wellbores). The reworked wells will serve the same purpose as other UGS wells, two gas storage wells and an observation 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 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 retrieving existing tubing string and packer; retrieving production liner; performing casing integrity wireline surveys; replacing existing wellhead; installing new production liner and gravel pack; and installation of new CalGEM compliant tubing string and packer. The reworks are 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. Rework of these wells would ensure that potential impacts to natural resources and the environment from compliance issues associated with the wells 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
Notice of Exemption
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