536911_Group_SPR_UIC

2025010624

California Department of Conservation (DOC)

NOE - Notice of Exemption

1/21/2025

1/21/2025

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

35°7'27.1"N 119°29'47"W

32S

23E

22

MD

Midway-Sunset Oil Field

Categorical Exemption

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

The project is exempt under the Class 1, Existing Facilities exemption because the project would make minor changes to existing wells involving no expansion of the existing use of the wells. Class 1 consists of the “minor alteration” of existing facilities “involving negligible or no expansion of existing or former use.” (14 CCR § 15301.) This includes “alteration of well casing, such as perforating and casing repair.” Additionally, in accordance with 14 CCR § 1684.1 the Class 1 exemption consists of operation, repair, maintenance, minor alternation of existing public or private structures, facilities, mechanical equipment, or topographical features involving negligible or no expansion of use beyond that existing previously. This Class includes but is not limited to conversion, and abandonment work on oil, gas, injection, and geothermal wells involving the alteration of well casing, such as perforating and casing repair, removal, or replacement; installation or removal of downhole production or injection equipment, cement plugs, bridge plugs, and packers set to isolate production or injection intervals. The project consists of reworking 9 existing injection wells to plug back an existing perforation interval with cement and add perforations to the same reservoir as the existing completion interval. No expansion of the existing well pads, roads, staging areas, or pipelines are proposed, and the completion design would be the same as the original wellbores. According to a CalGEM engineer, the proposed work is within the scope of UIC project 46400385 and would be a continuation of operations within the confines of the UIC project as permitted by the project approval letter (PAL). Therefore, the changes to the existing facilities would be negligible and would not expand the existing use. 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 that 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.

Categorical Exemption

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

Class 2 exemption 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, “[r]eplacement or reconstruction of existing utility systems and/or facilities involving negligible or no expansion of capacity.” The project would include reworking 9 wells to pull and replace tubing, plug back an existing perforation interval with cement, and add perforations to the same reservoir as the existing completion interval, and the completion design would be the same as the original wellbores. According to a CalGEM engineer, the proposed work is within the scope of UIC project 46400385 and would be a continuation of operations within the confines of the UIC project as permitted by the PAL. Therefore, the proposed project consists of replacement or reconstruction and would not change the purpose or capacity of the wells. 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 that 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.

Categorical Exemption

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

Class 4 exemption applies. Class 4 consists of “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.” (14 CCR § 1684.2; see also 14 CCR § 15304). The proposed project would be conducted entirely on existing pads with enough space to contain all equipment. The project would include reworking 9 existing injection wells to plug back an existing perforation interval with cement and add perforations to the same reservoir as the existing completion interval, and the completion design would be the same as the original wellbores. No expansion of the existing well pads, roads, staging areas, or pipelines are proposed. 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.” 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 that 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.