599607_Group_PG&E_UGS

2024110587

California Department of Conservation (DOC)

NOE - Notice of Exemption

11/19/2024

11/19/2024

Nicole Trezza

Department of Conservation, Geologic Energy Management Division

CEQA Program Contractor

Lead/Public Agency

715 P Street, MS 1803
Sacramento, CA 95814

(916) 445-9686

CEQA@conservation.ca.gov

38°1'32"N 122°0'26.2"W

02N

01W

18

MD

Los Medanos Gas Field

Categorical Exemption

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

Class 1 exemption applies under CalGEM’s regulations and section 15301(b) of the CEQA Guidelines. 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.” (§ 1684.1.) CEQA section 15301(b) Class 1 exemptions allow for: “Existing facilities of both investor and publicly-owned utilities used to provide electric power, natural gas, sewerage, or other public utility services[.]” The UGS facility is an existing facility of an investor-owned utility that is used to provide natural gas services and is an integrated component of the natural gas transmission process. The purpose of the permitted activity is to make up for lost deliverability due to previous plug and abandonment work associated with ongoing inspections to comply with CalGEM’s 2018 regulations that establish standards for the design, construction, and maintenance of all gas storage wells. Deliverability is the measure of the amount of gas that can be delivered (withdrawn) from a storage facility on a daily basis. Because the permitted activity is to make up for lost deliverability, the replacement wells will enable the facility to operate in substantially the same manner with substantially the same capacity before capacity was lost. In addition, the proposed project will not increase the gas injection or withdrawal rates, beyond what the facility is permitted for by the CPUC. Accordingly, the permitted activity satisfies the requirements of the Class 1 exemption.

Categorical Exemption

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

Class 2 applies because the proposed project 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, “[r]eplacement or reconstruction of existing utility systems and/or facilities involving negligible or no expansion of capacity.” The proposed project involves the installation of new replacement gas storage wells at an existing UGS utility facility. The purpose of the new storage wells is to replace wells that were converted to tubing and packer and outage (i.e., plugged and abandoned) associated with the ongoing inspections in compliance with CalGEM’s 2018 regulations. The 2018 regulations establish standards for the design, construction, and maintenance of all gas storage wells. The new replacement gas storage wells will be installed on existing well pads within the existing gas storage facility and no additional construction will occur. The replacement gas storage wells will serve the same purpose as the wells that have been plugged and abandoned and are necessary for the facility to provide the same measure of deliverability capacity. The permitted activity will not result in an expansion in gas compressor capacity, nor will there be an expansion of the injection and withdrawal rates. Therefore, the replacement wells satisfy the requirements of the Class 2 exemption.

Categorical Exemption

Class 3: California Code of Regulations, title 14, section 15303

Class 3 applies to the proposed project. Class 3 “consists of construction and location of limited numbers of new, small facilities or structures” and “installation of small new equipment and facilities in small structures.” An example of the exemption includes “[w]ater main, sewage, electrical, gas, and other utility extensions[.]” (14 CCR § 15303(d).) Because the proposed project involves the installation of two new, small structures in a natural gas facility, and the structure is an extension of the natural gas transmission process, the project is categorically exempt under the Class 3 exemption.

Categorical Exemption

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

Class 4 applies to the proposed project. Under the CEQA Guidelines, Class 4 “consists of minor or public or private alterations in the condition of land, water, and/or vegetation which do not involve removal of healthy mature, scenic trees except for forestry and agricultural purposes.” CalGEM’s regulations define Class 4 as “drilling operations that result only in minor alterations with negligible or no permanent effects to the existing condition of the land, water, air, and/or vegetation.” The project would be conducted entirely on existing pads of sufficient space to contain all equipment, and existing roads to the pads would be utilized with no new disturbance. As explained in the preliminary review, no impacts to biological resources are expected. No trees would be removed, and the project would not otherwise disturb any undisturbed areas. Therefore, the project would result in only minor alterations with negligible or no permanent effects to land, water, air, and/or vegetation.