607257_SoCalGas_UGS

2024120115

California Department of Conservation (DOC)

NOE - Notice of Exemption

12/4/2024

12/4/2024

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

34°26'55.5"N 118°35'28.8"W

04N

15W

07

SB

Honor Rancho Gas Field

Categorical Exemption

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

Class 1 exemption applies to the rework of this existing gas storage 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.) Under CEQA Guidelines section 15301(b), the Class 1 exemption “consists of the operation, repair, maintenance, permitting, leasing, licensing, or minor alteration of existing public or private structures, facilities, mechanical equipment, or topographical features, involving negligible or no expansion of existing or former use,” where existing facilities may include “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 inspect the well integrity and remediate identified conditions as part of the SIMP. This project includes pulling kill string, perform casing expansions, monitor the well, run inspection logs and pressure test, install new completion equipment, running the LET, and monitoring the effectiveness of LET for potential remediation of micro-anulus to comply with CalGEM’s 2018 regulations that establish standards for the design, construction, and maintenance of all gas storage wells. The proposed activities will enable the facility to operate in substantially the same manner. 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.

Categorical Exemption

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

Class 2 applies because the rework 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 rework of an existing gas storage well at an existing UGS utility facility. The intent of this project is to inspect the well integrity and remediate identified conditions as part of the SIMP. This project includes pulling kill string, perform casing expansions, monitor the well, run inspection logs and pressure test, install new completion equipment, and running the LET. CalGEM’s 2018 regulations establish standards for the design, construction, and maintenance of all gas storage wells. The activities will be performed on an existing well pad within the existing gas storage facility. The well will continue to serve the same purpose of gas storage and is 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.

Categorical Exemption

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

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 an existing pad of sufficient space to contain all equipment, and existing roads to the pad 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.