590118_SoCalGas_UGS

2024071097

California Department of Conservation (DOC)

NOE - Notice of Exemption

7/29/2024

7/29/2024

Jan Perez

Department of Conservation, Geologic Energy Management Division

Senior Environmental Scientist

Lead/Public Agency

715 P Street, MS 1803
Sacramento, CA 95814

(916) 445-9686

jan.perez@conservation.ca.gov

34°27'3.4"N 118°36'4.2"W

API # 0403730595 Well Name: WEZU 25 D Honor Rancho Gas Field

Categorical Exemption

14 CCR §§ 15301, 1684.1

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 Project includes rework of an existing well, to return to service, and includes pulling a 3-1/2" kill string, pulling the retrievable bridge plug, making a clean out/feeler run to bottom of liner, pressure testing and logging the 9-5/8" casing, and running new 4-1/2" tubing (including a production packer). This required well construction upgrade will maintain or diminish the throughput capacity of the reworked gas storage well resulting in negligible or no expansion of the existing use. This rework is considered remedial because it is attendant to compliance with CalGEM’s heightened well construction standards and safety regulations and involves associated maintenance of the well in order to ensure continued operation.

Categorical Exemption

14 CCR §15302

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 rework involves pulling a 3-1/2" kill string, pulling the retrievable bridge plug, making a clean out/feeler run to bottom of liner, pressure testing and logging the 9-5/8" casing, and running new 4-1/2" tubing (including a production packer) to enhance the safety of the UGS Project. 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 and continue to provide the same measure of deliverability or capacity.

Categorical Exemption

14 CCR §§ 15304, 1684.2

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, and when combined with existing roads, has 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 rework would not expand the facility and is conducted in order to comply with CalGEM safety regulations (remedial) and maintain level of service.

Categorical Exemption

14 CCR §§ 15307, 15308

Classes 7 and 8, Actions by Regulatory Agencies for 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 rework involves pulling a 3-1/2" kill string, pulling the retrievable bridge plug, making a clean out/feeler run to bottom of liner, pressure testing and logging the 9-5/8" casing, and running new 4-1/2" tubing (including a production packer) to comply 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 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 would assure the maintenance, restoration, enhancement, and/or protection of a natural resource and the environment. Exceptions to Exemptions: CalGEM further finds that there are no exceptions to the application of the categorical exemptions (PRC § 21084; 14 CCR § 15300.2) referenced above. For example, there is no substantial evidence that there are any “unusual circumstances” associated with the proposed Project that create a reasonable possibility that the activity will have a significant effect on the environment, and there are no significant “cumulative impacts” resulting from successive projects of the same type in the same place. Therefore, reliance on the exemptions is appropriate. Consistent with the purposes of PRC § 3250 et seq. and the documentation available for the preliminary review, the proposed Project will benefit the environment. In addition, the work under the contracts and any resulting impacts will be temporary in duration. Therefore, the Project can be considered exempt from the need for full CEQA review.