UROW Inspection Program Overview

A key requirement of PRC section 3185 is that inspections of “some” gas storage wells are to be performed annually. CalGEM has determined to inspect approximately 25% of wells statewide annually through its UROW Inspection Program. The UROW Inspection Program is an addition to, and does not replace, CalGEM’s other inspections and onsite regulatory oversight. Since CalGEM updated its UROW inspection process effective in mid-2022, this report covers gas storage wells that were selected and inspected the second half of the year, approximately 12.5% of all gas storage wells statewide (Figure 1). In 2023, CalGEM’s goal is to inspect 25% of wells statewide.

A second key requirement of PRC section 3185 is that inspections are to be performed at “random.” CalGEM fulfills this requirement by selecting “at random” approximately 25% of all gas storage wells statewide. CalGEM uses the resulting list for that year’s UROW Inspection program.

Another key requirement is that inspections be “unannounced.” CalGEM does not share its inspection well list with UGS operators, and CalGEM’s field engineers arrive at each UGS field (where the UGS facility is located) without advance warning to the operator being inspected. During a UROW inspection, the CalGEM field engineer visits the site of one of the wells previously selected at random, and completes (1) an Environmental Well Inspection (a visual inspection of the wellhead, cellar, and surrounding area of a gas storage well) and may (2) complete a Gas Leak Detection Inspection employing a Forward Looking InfraRed (FLIR) gas detection camera. A gas leak detection inspection is a visual inspection conducted using FLIR cameras to look for evidence of leaking gas storage wells. This type of inspection is conducted if a FLIR camera is available for use and the inspector is FLIR-Certified. CalGEM’s goal is to include as many Gas Leak Detection Inspections as possible during UROW inspections.

The timing of UROW inspections is intended to be unpredictable, consistent with the intent of PRC section 3185. CalGEM field engineers may conduct a UROW inspection of any well on the list at any time during the calendar year.

If the CalGEM engineer identifies a violation during an inspection, the operator is sent a Notice of Violation (NOV) through CalGEM’s reporting software, WellSTAR, and is required to remediate each identified violation, typically within 30 days. If the operator does not remediate the violation in an appropriate or timely manner, CalGEM may pursue appropriate enforcement action, including issuance of a remedial order, imposition of civil penalties, or other remedies. CalGEM’s district offices are primarily responsible for performing inspections, documenting violations, and overseeing compliance work.

The next two sections outline the regulations most relevant to UROW Inspections and describe how to read the inspection tables. Results of the UROW Inspections performed during the reporting period can be viewed in tables 1 through 8, which are broken down by UGS field.

Regulatory Information for UROW Inspections

During UROW inspections, CalGEM enforces the following regulatory requirements to help protect life, health, property, the environment, and natural resources. Specifically, the Environmental Well Inspection evaluates the following conditions: well identification, presence of refuse or waste, presence of fluid in well cellars, well cellar adequately covered, well leakage, well and wellhead appropriately closed and secured, weeds not posing a fire hazard, access road adequately maintained, and adequate perimeter fencing for wells in urban locations. The Gas Leak Detection Inspection, utilizing CalGEM’s FLIR cameras, is aimed at detecting gas leaks from gas storage wellheads at the surface.

Reading Inspection Data Tables

UROW Inspection data tables 1 to 8 are provided below, one for each gas storage field. Each data table has seventeen columns, read from left to right. The meaning of each column heading is described below. The first six column headings relate to well specific information and include: API, Operator, Well Status, UGS Project ID, Critical Well, and Environmentally Sensitive. The next eleven column headings relate to inspection information and include: Inspection Date, Well Sign, Refuse/Trash, Fluids in Cellar, Cellar Covered, Well Leaking, Well Open at Surface, Weeds Present, Access Road, and Urban Enclosure). For each well inspected at the facility covered by the given table, there is a unique row with information contained for that well and its inspection result.

Each column heading has a unique meaning. “API” means the unique and permanent number assigned to each well as standardized by the American Petroleum Institute.

“Operator” is the name of the business entity that operates the gas storage field that is the subject of that table.

“Well” is the legal name of a well denoted by the lease name, followed by the well number. The well number is an alpha-numeric designation that the operator assigns to the well.

“Status” is a code indicating that at the time of the inspection, the well was Active (in current or recent use), Idle (has not been used for 2 or more years), or Plugged (Cemented to surface and no longer a viable well).

“UGS Project ID” is an identifier used to denote which UGS project is associated with a gas storage well.

“Critical Well” - A critical well is defined by law as a well located within either 300 feet of any building intended for human occupancy that is not necessary to the operation of the well, or any airport runway. OR a well located within 100 feet of any dedicated public street, highway, or nearest rail of an operating railway that is in general use; any navigable body of water or watercourse perennially covered by water; any public recreational facility such as a golf course, amusement park, picnic ground, campground, or any other area of periodic high-density population; or any officially recognized wildlife preserve.

“Environmentally Sensitive” - This term refers to any of the following: a production facility within 300 feet of any public recreational area, or a building intended for human occupancy that is not necessary to the operation of the production operation, such as residences, schools, hospitals, and businesses; a production facility within 200 feet of any officially recognized wildlife preserve or environmentally sensitive habitat that is designated on a United States Geological Survey topographical map, designated waterways, or other surface waters such as lakes, reservoirs, rivers, canals, creeks, or other water bodies that contain water throughout the year; a production facility within the coastal zone as defined in PRC section 30103, subdivision (b); or any production facility which the State Oil and Gas Supervisor determines may be a significant potential threat to life, health, property, or natural resources in the event of a leak, or that has a history of chronic leaks.

The “Critical Well” and “Environmentally Sensitive” column entries are noted as either “Yes” or “No,” indicating whether or not the well meets the definition of a critical well or is located within an environmentally sensitive area.

“Inspection Date” indicates the month, day, and year the UROW inspection was performed for the listed well.

The next ten columns in the inspection summary tables indicate the results of the inspection of each of the individual elements identified in the column headings. These columns are noted as either “Pass” or “Violation.” A “Pass” means that the field engineer did not identify any concerns with that element. A notation of “Violation” means that the inspection identified non-compliance with the specific requirement covered by the heading. For some inspections, information may be inapplicable (i.e., urban well enclosure is not applicable in non-urban settings); in those circumstances, there will be a notation of “N/A” meaning not Applicable.

The ten columns summarizing inspection results with either a Pass or Violation or N/A noted are defined as follows:

The “Well Sign” column indicates whether the well had adequate signage posted in a conspicuous location and containing all legally required information.

The “Refuse/Trash” column indicates whether the well site was free of oilfield wastes and other refuse.

The “Fluids in Cellar” column indicates whether the well cellar, the area excavated around the wellhead, is free of wellbore or other fluids which can increase corrosion in wellheads and as to exclude people and animals.

The “Cellar Covered” column indicates whether the well cellar was covered and secure, so as to exclude people and animals.

The “Well Leaking” column indicates whether gas was detected at the wellhead.

The “Well Open at Surface” column indicates whether the well casing, tubing or associated piping is an open pipe and is lacking connections to other equipment or pipe.

The “Weeds Present” column indicates whether the well site was free of weeds and other growth which might pose a fire hazard.

The “Access Road” column indicates whether the road accessing the well location was maintained in a safe and passable condition.

The final column, “Urban Enclosure” indicates whether the well and related production facilities were adequately fenced.

Figure 1

Figure 1: Number of wells per field that are required to have UROW inspections completed for 2022.

Table 1. Aliso Canyon

Table 2. Gill Ranch Gas

Table 3. Honor Rancho

Table 4. La Goleta Gas

Table 5. Lodi Gas

Table 6. McDonald Island Gas

Table 7. Playa Del Rey

Table 8. Wild Goose Gas