609417_Group_PG&E_UGS
Summary
SCH Number
2024110588
Public Agency
California Department of Conservation
(DOC)
Document Title
609417_Group_PG&E_UGS
Document Type
NOE - Notice of Exemption
Received
Posted
11/19/2024
Document Description
The permitted activity is a new drill and a sidetrack of two underground gas storage (UGS) wells in the McDonald Island Gas Storage Field. Drilling activity will be performed on existing pads, and existing roadways will be used for access. New drill activity will include directional drilling to bottom hole location approximately 5,400' below surface. New casing will be installed and cemented to the surface. New CalGEM compliant tubing and packer will be installed. The rework will be conducted in order to meet CalGEM Underground Gas Storage inspection and construction requirements as specified in 14 CCR § 1726 et seq.
The permitted activity consists of CalGEM approving two permits for PG&E to sidetrack and drill the UGS wells listed below, in the McDonald Island Gas Storage Field.
API # Well Name
N/A (New Drill) TC-01B-S
0407720467 WS-19W
Contact Information
Name
Nicole Trezza
Agency Name
Department of Conservation, Geologic Energy Management Division
Job Title
CEQA Program Contractor
Contact Types
Lead/Public Agency
Phone
Email
Location
Coordinates
Counties
San Joaquin
Regions
Countywide, Statewide
Township
02N
Range
04E
Section
25
Base
MD
Other Location Info
McDonald Island Gas Storage Field
Notice of Exemption
Exempt Status
Categorical Exemption
Type, Section or Code
Class 1: California Code of Regulations, title 14, section 15301
Reasons for Exemption
Class 1 exemption applies to the sidetrack and new replacement well 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 exemption allows for: “Existing facilities of both investor and publicly-owned utilities used to provide electric power, natural gas, sewerage, or other public utility services[.]” As this facility is a natural gas public utility service, it would qualify for a Class 1 exemption under § 15301(b). 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 proposed activities 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 proposed activity is to make up for lost deliverability, the activities will enable the facility to operate in substantially the same manner as it did 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 proposed activity satisfies the requirements of the Class 1 exemption.
Exempt Status
Categorical Exemption
Type, Section or Code
Class 2: California Code of Regulations, title 14, section 15302
Reasons for Exemption
Class 2 applies because the sidetrack and new drill activities consist 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 sidetrack of an existing well and the installation of a new replacement gas storage well at an existing UGS utility facility. The purpose of the proposed activities is to replace wells that were converted to tubing and packer and outage (i.e., thereby reducing capacity) 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 activities will be performed on existing well pads within the existing gas storage facility. The wells will serve the same purpose as the wells that have been modified and are necessary for the facility to provide the same measure of deliverability capacity. The proposed 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 activities proposed satisfy the requirements of the Class 2 exemption.
Exempt Status
Categorical Exemption
Type, Section or Code
Class 3: California Code of Regulations, title 14, section 15303
Reasons for Exemption
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 this exemption includes “[w]ater main, sewage, electrical, gas, and other utility extensions.” (14 CCR § 15303(d).) Because the proposed project involves the installation of small structures in a natural gas facility, and the structures are an extension of the natural gas transmission process, the project is categorically exempt under the Class 3 exemption.
Exempt Status
Categorical Exemption
Type, Section or Code
Class 4: California Code of Regulations, title 14, section 15304
Reasons for Exemption
Class 4 applies to the proposed activities. 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 this PR, 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.
County Clerk
San Joaquin
Attachments
Notice of Exemption
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