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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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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 A certificate of public convenience and necessity or certificate of public convenience regulatory compliance
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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
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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
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Gas Storage Fields in California
Year Established Field Working Gas (BCF) 1941 La Goleta 21.5 1942 Playa Del Rey 2.4 1973 Aliso Canyon 86.0 1975 Honor Rancho 24.2 Kirby Hills 15.0 1976 McDonald Island 82.0 1979 Los Medanos 18.0 Pleasant Creek 2.3 1997 Wild Goose 75.0 2001 Lodi 17.0 2010 Princeton 11.0 Gill Ranch 20.0 Total 385.4
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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 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 On Dec issued Order 1106 not to inject into the storage reservoir until order is lifted On March 4, 2016 Issued Order 1109 to perform comprehensive Safety Review
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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
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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 to determine the feasibility of minimizing or eliminating use of the Aliso Canyon natural gas storage facility
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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
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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
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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)
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