Article 3.5 - Natural Gas Storage Wells

California Public Resources Code — §§ 3180-3187

Sections (10)

Added by Stats. 2016, Ch. 673, Sec. 3. (SB 887) Effective January 1, 2017.

(a)As used in this article, “gas storage well” means an active or idle well used primarily to inject natural gas into or withdraw natural gas from an underground natural gas storage facility.
(b)On or before January 1, 2018, the operators of all gas storage wells shall have commenced a mechanical integrity testing regime specified by the division. The testing regime shall include all of the following:
(1)Regular leak testing.
(2)Casing wall thickness inspection.
(3)Pressure test of the production

casing.

(4)Any additional testing deemed necessary by the division to demonstrate the integrity of the well.
(c)All anomalies identified in the testing shall be immediately reported to the appropriate district office and explained to the supervisor’s satisfaction.
(d)(1) The division shall promulgate regulations that establish standards for the design, construction, and maintenance of all gas storage wells to ensure that integrity concerns with a gas storage well are identified and addressed before they can become a threat to life, health, property, the climate, or natural resources.
(2)The regulations shall require that gas storage wells be designed, constructed, and maintained to ensure that a single point of failure does not

pose an immediate threat of loss of control of fluids, as determined by the supervisor.

(3)In developing the regulations, the division shall consider enhanced design, construction, and maintenance measures that could meet the standard in paragraph (2), including any of the following:
(A)Primary and secondary mechanical well barriers to isolate the storage gas within the storage reservoir and transfer storage gas from the surface into and out of the storage reservoir.
(B)Production casing to the surface with the required integrity to contain reservoir pressure.
(C)Tubing and packer and production tree with the required integrity to contain reservoir pressure.
(D)Surface controlled

subsurface safety valves or Christmas tree valves with the required integrity to contain reservoir pressure that halt flow through the well.

(E)Secondary barrier with overlapping cement casing between two concentric casings with good quality cement bond.
(F)Wellhead with annular valves and seals and the required integrity to contain reservoir pressure.
(G)Casing with a hanger and seal assembly.
(H)Any other well construction requirements the supervisor determines would improve the protection of public health, safety, the environment, and natural resources.
(4)In developing the regulations, the division shall develop a schedule for ongoing mechanical integrity testing.
(e)In order to facilitate consistency, standardization, and training for site inspection and maintenance, to the extent that the regulations promulgated by the division pursuant to subdivision (d) address surface equipment associated with an underground gas storage facility, the division shall ensure that those regulations are consistent with comparable requirements in Parts 190 to 199, inclusive, of Title 49 of the Code of Federal Regulations.

Added by Stats. 2016, Ch. 673, Sec. 3. (SB 887) Effective January 1, 2017.

(a)The operator of a gas storage well shall submit for the supervisor’s approval the following materials:
(1)Data describing the gas storage project and gas storage wells that demonstrate that stored gas will be confined to the approved zone or zones. Updated data shall be provided to the division if conditions change or if more accurate data become available.
(2)A risk management plan to identify and plan for mitigation of all threats and hazards and potential threats and hazards associated with gas storage well operation in order to ensure internal and external mechanical integrity of a well, including site-specific information. The

risk management plan shall provide for regular review and revision, as needed, to ensure the plan appropriately reflects current conditions. The risk management plan shall include, but is not limited to, all of the following:

(A)A natural gas leak prevention and response program that addresses the full range of natural gas leaks possible at the facility with specific response plans that provide for immediate control of the leak. The operator shall consult with local emergency response entities on the response plans. The prevention and response program shall include, but is not limited to, all of the following:
(i)A protocol for public notice of a large, uncontrollable leak to any potentially impacted community, as defined in the risk management plan, if the leak cannot be controlled within 48 hours of discovery by the operator.

(ii) Prepositioning, as feasible, and identification of materials and personnel necessary to respond to leaks. This shall include materials and equipment to respond to and stop the leak itself as well as to protect public health.

(iii) The identification of personnel responsible for notifying regulatory authorities with jurisdiction over the range of leaks possible.

(B) A plan for corrosion monitoring and evaluation.

(C) A schedule for regular well and reservoir integrity assessments.

(D) An assessment of the risks associated with the gas storage well and its operation.

(E) Planned risk mitigation efforts.

(F) A regular maintenance program for the well and the portion of the facility within the division’s jurisdiction. The maintenance program shall include training for site personnel and proactive replacement of equipment at risk of failure to ensure safe operation.

(3)In addition to other factors deemed relevant by the supervisor, the risk management plan required in paragraph (2) shall consider all of the following:
(A)The facility’s distance from dwellings, other buildings intended for human occupancy, or other well-defined outside areas where people may assemble such as campgrounds, recreational areas, or playgrounds.
(B)The risks to and from the well related to roadways, rights of way, railways, airports, and industrial facilities.
(C)Proximity to environmentally or culturally sensitive areas.
(D)The risks of well sabotage.
(E)The current and predicted development of the surrounding area.
(F)Topography and local wind patterns.
(b)All of the materials described in subdivision (a) shall be reported to the division according to a schedule approved by the supervisor. The operator shall not deviate from the programs, plans, and other conditions and protocols contained in the materials without prior written approval by the supervisor.

Added by Stats. 2019, Ch. 773, Sec. 3. (SB 463) Effective January 1, 2020.

(a)(1) The operator of a gas storage well shall provide to the division a complete chemical inventory of the materials, of any phase, that may be emitted from the gas storage well in the event of a reportable leak, as defined for purposes of Section 3183, periodically, as determined by the division, but no less than annually. For purposes of this section, material includes, but is not limited to, the composition of formation fluids, gas in the storage reservoir, wellbore-produced fluids, and all well maintenance and

control materials, including well kill fluids, placed in the well.

For purposes of this section, fluids include suspended or entrained solids.

(2)The division shall consider information collected pursuant to its existing regulations when determining what information satisfies the requirements of this section.
(b)Notwithstanding subdivision (a), in the event of a reportable leak, as defined for purposes of Section 3183, the operator of a gas storage well shall provide to the division the composition of well kill

fluids within five days of their use in a leaking gas storage well and any updates to the information reported pursuant to subdivision (a) to ensure that it is current.

(c)The information provided pursuant to this section shall be provided with sufficient accuracy and precision as determined by the division, in consultation with the Office of Environmental Health Hazard Assessment and other relevant health experts, to inform the determination of public health impacts from the release of these materials to the environment.
(d)If an operator subject to this section is unable to obtain information about a chemical from the chemical’s supplier for any reason, including, but not limited to, assertion by the chemical supplier of trade secret protections, the division may require the supplier to furnish that information to the division.
(e)In the event of a reportable leak, as defined for purposes of Section 3183, the division shall post the information related to the reportable leak received pursuant to this section on its internet

website.

Added by Stats. 2016, Ch. 673, Sec. 3. (SB 887) Effective January 1, 2017.

On a weekly basis, the division shall post a list of notices received pursuant to Section 3203 on the division’s Internet Web site. Copies of any notice shall be provided to members of the public upon request.

Amended by Stats. 2019, Ch. 773, Sec. 4. (SB 463) Effective January 1, 2020.

(a)The division, in consultation with the State Air Resources Board, shall determine and adopt by regulation what constitutes a reportable leak from a gas storage well and the timeframe for reporting that leak. The regulations shall require an operator to immediately report to the division a leak that poses a significant present or potential hazard to public health and safety, property, or to the environment.
(b)Until the regulations pursuant to subdivision (a) are in effect, a leak of any size from a gas storage well shall be deemed a reportable leak, and the operator shall notify the division immediately.
(c)If a leak from a gas storage well that is reported to the division pursuant to subdivision (a) or (b), as applicable, cannot be controlled within 48 hours, the division shall post information about the leak on its internet website and provide regular updates to the public until the leak is stopped.
(d)The division, in consultation with the State Air Resources Board, shall review and, if necessary, revise the regulations developed pursuant to subdivision (a) no less than once every 10 years.

Added by Stats. 2016, Ch. 673, Sec. 3. (SB 887) Effective January 1, 2017.

(a)Within 72 hours of being notified of a reportable leak, pursuant to Section 3183, the supervisor shall determine if the reportable leak poses a significant present or potential hazard to public health and safety, property, or to the environment such that a relief well is necessary. If the supervisor makes that determination, the operator shall immediately begin preparation for, and, as soon as practicable at the determination of the supervisor, commence the drilling of, a relief well.
(b)Nothing in subdivision (a) shall prevent the supervisor from making a determination after the initial 72-hour period that a reportable leak poses a significant hazard to public health and safety, property, or to

the environment and that a relief well is necessary. If the supervisor makes that determination, the operator shall immediately begin preparation for, and, as soon as practicable at the determination of the supervisor, commence the drilling of, a relief well.

(c)If the operator is required to drill a relief well under subdivision (a) or (b), the operator’s efforts to drill the relief well shall continue until the reportable leak has been stopped and the cause of the reportable leak has been fully addressed or the supervisor determines that other means of controlling the reportable leak are appropriate.

Added by Stats. 2016, Ch. 673, Sec. 3. (SB 887) Effective January 1, 2017.

The division shall perform unannounced random onsite inspections of some gas storage wells annually. The results shall be posted and available to the public on the division’s Internet Web site.

Added by Stats. 2016, Ch. 673, Sec. 3. (SB 887) Effective January 1, 2017.

An operator of a gas storage well shall develop and maintain a comprehensive gas storage well training and mentoring program for those employees whose job duties involve the safety of operations and maintenance of gas storage wells and associated equipment. The training program shall include, but is not limited to, gas storage well operations, including best practices to prevent leaks, maintenance and testing, gas storage well safety regulations, emergency response, and incident reporting. If storage field employees are represented by a labor union, the operator shall consult with the relevant union local on safety issues and, when requested, establish a framework to provide training through a joint labor-management training program.

Added by Stats. 2019, Ch. 773, Sec. 5. (SB 463) Effective January 1, 2020.

On or before July 1, 2021, in response to the independent root cause analysis of the 2015 well leak at the Aliso Canyon gas storage facility prepared by Blade Energy Partners dated May 16, 2019, and ordered by the supervisor and the Public Utilities Commission, the division shall review and, if necessary, revise its natural gas storage well policy and regulations to address the root causes identified. At a minimum, the division shall evaluate and consider all of the following:

(a)Requirements for cathodic protection measures for well casings, where appropriate, on a well-by-well or field-by-field basis.
(b)Requirements for well control plans for a gas storage field, that include the range of flow properties possible in the event of an uncontrolled well

release.

(c)Requirements for investigating leaks and other pressure equipment integrity incidents that present a risk of leaks as determined by the division. This shall include reporting requirements to the division.

Added by Stats. 2016, Ch. 673, Sec. 3. (SB 887) Effective January 1, 2017.

All materials provided to the division and approved by the supervisor to comply with Sections 3181, 3184, and 3185 shall be posted and available to the public on the Internet Web site of the division in a timely manner.