586136_Harvest_UIC
Summary
SCH Number
2024110539
Public Agency
California Department of Conservation
(DOC)
Document Title
586136_Harvest_UIC
Document Type
NOE - Notice of Exemption
Received
Posted
11/18/2024
Document Description
The permitted activity consists of remediating a casing integrity issue by installing and cementing an inner casing, pressure testing to ensure mechanical integrity across the freshwater zone, and then returning the well back to injection within UIC 62606009 project area. A CalGEM engineer has confirmed that the proposed work is within the scope of UIC project 62606009 and would be a continuation of operations within the UIC project.
Based on information provided by Harvest Petroleum Inc. (the Operator) and confirmed by CalGEM, casing holes were discovered in the Lerdo 2 during a Standard Annular Pressure Test (SAPT) on Feb 22, 2023, and the well’s lack of mechanical integrity was reconfirmed during a rig-job from May 1 to July 6, 2023. During this rig-job, a retrievable bridge plug was set above the injection perforations at 3500 feet, and a test packer was used to attempt to locate the casing holes for repair via cement squeezes. Cement squeezes were unsuccessful at restoring mechanical integrity of the casing. The Operator described the threat as holes in the casing within a freshwater zone above the injection zone, which could lead to contamination from oilfield fluids into the freshwater zone if not addressed through repair.
With the base of fresh water at 3200 feet, the permitted activity to install a new inner casing and cement is necessary to prevent a potential threat to public health, safety, or the environment by repairing the casing so the well does not have a conduit to freshwater above the injection zone. The freshwater zone is one of many surface and underground sources of potential irrigation and/or drinking water.
Temporary surface equipment will be needed and will consist of a well service rig and ancillary equipment required to perform the casing repair work. No permanent facilities will be constructed. No expansion of associated facilities will be required.
Any waste generated will be sampled, tested, and disposed of at the appropriate licensed waste disposal site and sent to site under Uniform Manifest.
Water usage is estimated to be approximately 7,500 gallons. The water will be sourced produced water.
As confirmed by WellSTAR mapping, the well is located on an existing pad with access by existing roads. No disturbance to biological resources in the area is anticipated.
The permitted activity consists of CalGEM approving one permit to rework the oil and gas well listed below.
API # 0402985041
Well Name: Lerdo 2 Water Disposal
Contact Information
Name
Mikayla Vaba
Agency Name
Department of Conservation, Geologic Energy Management Division
Job Title
Environmental Planner
Contact Types
Lead/Public Agency
Phone
Email
Location
Coordinates
Counties
Kern
Regions
Southern California
Township
28S
Range
27E
Section
31
Base
MD
Notice of Exemption
Exempt Status
Statutory Exemption
Type, Section or Code
Emergency Project (PRC § 21080(b)(4); 14 CCR § 15269(c))
Reasons for Exemption
As the CEQA lead agency for the permitted activity, CalGEM has determined that the permitted activity is exempt from further environmental review requirements of CEQA, pursuant to the statutory exemption: Emergency Project (PRC § 21080(b)(4); 14 CCR § 15269(c).) because of the potential impacts to freshwater reservoirs due to a leaking casing. Therefore, immediate action is necessary to prevent or respond to a threat to public health, safety, or the environment.
Exempt Status
Categorical Exemption
Type, Section or Code
Class 1, Existing Facilities (14 CCR §§ 15301, 1684.1)
Reasons for Exemption
Class 1 applies to the permitted activity. Class 1 consists of the “operation, repair, maintenance, or minor alteration” of existing facilities involving “negligible or no expansion of use beyond that existing previously.” (§ 1684.1.) The project involves the maintenance and repair of a production well and does not include modifications or changes to an existing use. The permitted activity involves installing an inner casing and cementing on the well to seal the casing to eliminate potential impacts to freshwater reservoirs due to a leaking casing. The operator indicates that no permanent facilities would be constructed, and the project would not involve any new ground surface disturbance, including no new roads or other corridors. Therefore, there is no expansion of use beyond that previously existing. A CalGEM engineer has confirmed that the proposed work is within the scope of UIC project 62606009 and would be a continuation of operations within the UIC project.
Exempt Status
Categorical Exemption
Type, Section or Code
Class 2, Replacement or Reconstruction (14 CCR § 15302)
Reasons for Exemption
Class 2 applies to the permitted activity. Class 2 includes the “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.” This is a rework that involves installing an inner casing and cementing on the well to seal the casing to eliminate potential impacts to freshwater reservoirs due to a leaking casing and does not propose changes to the structure of the well (the wellbore). The location of the well would not change, nor would the underground structure of the well (the wellbore), nor would the purpose of the well, which is water injection.
Exempt Status
Categorical Exemption
Type, Section or Code
Class 7 & 8 Protection of Natural Resources and the Environment (14 CCR §§ 15307, 15308)
Reasons for Exemption
Class 7 and 8 also apply to the permitted activity. Class 7 and Class 8 include 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 well presents a concern that may increase the risk for adverse impacts to the environment or natural resources in the area due to the potential impacts to freshwater reservoirs due to a leaking casing. CalGEM has statutory and regulatory authority to protect natural resources and the environment. The Operator is required to repair the well under CCR section 1724.10, subdivision (i)(5), which requires an Operator to conduct necessary remedial work when an injection well fails a mechanical integrity test.
Attachments
Notice of Exemption
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