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Storage Fields in CA and Lessons Learned from Aliso Canyon Gas Storage Leak

Storage Fields in CA and Lessons Learned from Aliso Canyon Gas Storage Leak. Matthewson (Matt) Epuna Program and Project Supervisor California Public Utilities Commission This presentation product does not constitute the opinion of the Commission.

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Storage Fields in CA and Lessons Learned from Aliso Canyon Gas Storage Leak

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  1. Storage Fields in CA and Lessons Learned from Aliso Canyon Gas Storage Leak Matthewson (Matt) Epuna Program and Project Supervisor California Public Utilities Commission This presentation product does not constitute the opinion of the Commission.

  2. CA UNDERGROUND GAS STORAGE RESERVOIR REGULATORY STRUCTURE • Before and After October 23, 2015: • California Public Utilities Commission (CPUC) Regulates the horizontal gas pipeline (Gas Flow Lines) from the Wellhead to the Transmission pipeline(Flow Lines – upstream, Transmission and Local Distribution Center (LDC) • California Department of Conservation, Division of Oil, Gas, and Geothermal Resources (DOGGR) Regulates the vertical piping from the Wellhead to the tubulars/wellbore from the Wellhead to the production/injection zones

  3. CPUC STORAGE FIELD REGULATION • CPUC RULES AND REGULATIONS APPLIED TO GAS STORAGE FIELDS: • CA Public Utilities Code (CA PU Code) (Under CA Law, the Public Utilities Commission is authorized to supervise and regulate every public utility in the state) • General Order (G.O.) 112-F Referenced 49 CFR Parts 191,192, 199 and 40 • G.O 58 A & B • Commission Decisions & Directives

  4. DOGGR’s STORAGE FIELDS REGULATION • DOGGR’s APPLICABLE RULES AND REGULATIONS: • California Laws for the Conservation of Oil, Gas, and Geothermal Resources • California Code of Regulations (Title 14, Division 2, Chapters 2, 3 and 4) • Emergency Regulations Orders

  5. Gas Storage Fields in California

  6. ALISO CANYON INCIDENT TIMELINE • On Oct 23, 2015, SCG discovered a leak near SS-25 Well. • On Oct 24th, 2015, the first top kill operation conducted. (Six total attempts were made with the last one on November 25th 2015. None of them were effective) • On Nov 16, 2015, Relief Well #1 (P39A) Spud. • On Dec10, 2015, DOGGR Supervisor issued Order 1106 • On Feb 12, 2016, SS-25 was controlled from P39A. • Between Feb 15-18, 2016, SS-25 confirmed sealed. • March 4, 2016, DOGGR Supervisor issued Order 1109

  7. During Well Kill Operations • Well Kill Operation – Southern California Gas Co. (SCG), Boots & Coots and CA DOGGR • Incident Command Structure (ICS)- LA County FD • Air Monitoring for Methane & Other Constituents- SCG, CARB, SCAQMD and LA County Department of Public Health • Residents Relocation (approx. 8,000 residents relocated), and Cleaning of affected homes – SCG • Closed 2 Elementary Schools and Relocated Students & Instructional activities – School District • Projected Cost of Kill Operations, Recovery and Investigation is in Excess of $500 M

  8. INVESTIGATIONS • There Are Three Active Parallel Investigations and Safety Review: • CPUC Investigation – Determine Cause, Verify Compliance and Prevent Recurrence Per G.O. 112-F and PU Code • DOGGR Investigation - Determine Cause, Verify Compliance and Prevent Recurrence Per its Rules and Regulations • BLADE ENERGY PARTNERS – Perform complete Root Cause Analysis (RCA) • DOGGR Safety Review – Per Division Supervisor’s Emergency Orders (Conduct Batteries of Tests) • CPUC, no later than July 1, 2017, open a proceeding to determine the feasibility of minimizing or eliminating use of the Aliso Canyon natural gas storage facility

  9. LESSONS LEARNED • Regulators, SCG and Stakeholders Take Away the Following Lessons Learned: • Importance of Gas Storage to LA Basin (Reliability impacts on Electric Generators and Industrial Customers) • Establish in early stage a Unified Incident Command Structure (ICS) • ICS Commander to designate Access Control & Restrictions • Establish Roles and Responsibilities and designate Contacts • Establish Effective and Efficient Communication Systems • Establish Effective Response Systems to Address Public Concerns • Establish and Coordinate Environmental Monitoring with Affected Agencies

  10. LESSONS LEARNED Cont’d • Establish Plan to Educate Responding Agencies about Underground Gas Storage Operations especially before an Emergency • Establish Inter Agency Coordination • Urgent Need to Update Rules and Regulations to Address: • Well Construction Standards • Integrated Storage Well Risk Management Program • Advance Monitoring and Testing Program that includes MIT • Improved Inspection Regime and Frequency • Comprehensive Emergency Response Plans and Notification • Land Use Permitting

  11. LESSONS LEARNED Cont’d • Urgent Need to Mandate Implementation of Storage Well Integrity Management Program, Identical to Transmission Pipeline Integrity Management Program (TIMP) that Addresses: • Data gathering and Integration • Threats and Hazards Identification • Risk Analysis & Prioritization • Remediation and Implementation of Preventative and Mitigative Measures • Continual Well Integrity Evaluation and Reassessment of Threats and Hazards • Limiting Injection and Withdrawal through Production Tubing Only (prohibition of injection and withdrawal through Casing annulus)

  12. Thank you! For Additional Information: www.cpuc.ca.gov EMA@CPUC.CA.GOV

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