Analysis of Oil and Gas Well Stimulation Treatments in California 7. DESCRIPTION OF THE PROJECT 7. Description of the Project 7.1 Introduction As described in EIR Chapter 4 (Scope and Intent of the Environmental Impact Report), SB 4 requires the preparation of an EIR “to provide the public with detailed information regarding any potential environ- mental impacts of well stimulation in the State” (PRC Section 3161(b)(3) of Division 3, Chapter 1, as amended). Further, SB 4 requires that the EIR address those stimulation treatments for oil and gas wells “that may occur at oil wells in the state existing prior to, and after, January 1, 2014” (PRC Section 3616(b)(3)(B)(ii) of Division 3, Chapter 1, as amended). PRC Section 3157 of Division 3, Chapter 1, as amended, defines oil and gas well stimulation as “any treat- ment of a well designed to enhance oil and gas production or recovery by increasing the permeability of the formation. Well stimulation treatments include, but are not limited to, hydraulic fracturing treat- ments and acid well stimulation treatments. Well stimulation treatments do not include steam flooding, water flooding, or cyclic steaming. Additionally, such treatments do not include routine well cleanout work, routine well maintenance, routine removal of formation damage due to drilling, bottom hole pressure surveys, or routine activities that do not affect the integrity of the well or the formation. Con- sequently, this EIR also does not evaluate high rate gravel packing1 when it is used to control sand within a well. Hydraulic and Ggravel (i.e., sand) packing treatments (“frac packing”) that are performed for well stimulation with the intent for the purpose of fracturing the formation are covered under the descrip- tion of hydraulic fracturing in EIR Section 7.4.1 (Hydraulic Fracturing). For the purposes of this EIR, the “Project” focuses on the physical acts that are associated with hydraulic fracturing, acid fracturing, and acid matrix stimulation as they apply to both existing and future oil and gas wells within the State. The physical activities associated with these stimulation treatments are described below in EIR Section 7.4 (Oil and Gas Well Stimulation Treatments). In this EIR they are analyzed with consideration of DOGGR’s implementation of the proposed permanent regulations that would amend California Code of Regulations Title 14, Division 2, Chapter 4, Subchapter 2 (see EIR Chapter 2 [Regula- tory Framework for the Division of Oil, Gas and Geothermal Resources]). This EIR’s analysis assumes that these well stimulation treatments could occur either within or outside of existing oil and gas field boundaries, as further described in EIR Chapter 9 (Overall Approach to the Environmental Analysis). 7.2 Project Objectives Section 15124(b) of the State CEQA Guidelines requires that an EIR’s “Project Description” include a clearly written statement of a proposed project’s objectives to help a Lead Agency develop a reasonable range of alternatives, and aid its decision making body when preparing Findings of Fact and a Statement of Overriding Considerations, if necessary. Unlike most EIRs, which are typically prepared in response to a specific project proposal such as a permit application or proposed legislative action, this EIR has been prepared in response to the mandate set forth in PRC Section 3161, Subdivisions (b)(3)(A) and (B), as enacted pursuant to SB 4 from the 2013 legislative session and later amended by SB 861 in 2014 (Stats. 2014, ch. 35). Accordingly, this EIR has not been prepared in response to a specific project proposal, but rather is an informational document regarding the potential impacts of well stimulation which may serve 1 High rate gravel packing is a technique where the annulus (the space between the casing and the drilled hole or wellbore) of a well is packed, at a high pumping rate, with gravel, water, and additives to limit the entry of fines and sand from the formation into the wellbore. The size of the gravel is similar to the size of the proppant (sand) described in EIR Section 7.4.1 for hydraulic fracturing. June 2015 7-1 Final EIR Analysis of Oil and Gas Well Stimulation Treatments in California 7. DESCRIPTION OF THE PROJECT to inform other CEQA documents. The statute (as amended) adds that section 3161 “does not prohibit a local Lead Agency from conducting its own EIR.” SB 4 also directs other State, regional and local agencies, in collaboration with DOGGR, to establish their respective authority, responsibility, notification and reporting requirements as related to various aspects of well stimulation treatments. Although the execution of some of SB 4’s requirements are independent and exclusive of each other, they are all inter-related in the sense that they all serve the overall objec- tive of SB 4 of requiring the State to rigorously evaluate well stimulation treatments and determine whether they can be conducted safely and with minimal impacts to the environment. To this end, the over-arching objectives of this EIR are not limited to oil and gas well stimulation treatments alone, but also include the objectives of the proposed permanent regulations, as listed below. 1. Objectives of Oil and Gas Well Stimulation Treatments a. To increase the recovery of oil and gas resources by increasing the reservoir permeability to create an economically feasible production rate from presently unusable formations. b. To minimize the number of new wells required for the recovery of hydrocarbon resources. c. To maximize the efficiency and production capacity of existing and planned oil and gas wells. d. To allow continued development of the State’s hydrocarbon resources. e. To conduct well stimulation treatments safely to minimize impacts to the environment and nat- ural resources. f. To reduce the State’s and nation’s reliance on foreign oil and gas resources. 2. Objectives of the Environmental Impact Report a. To comply with PRC Section 3161, Subdivision (b)(3)(A) and (B), by providing the public with detailed information regarding the practice of well stimulation. b. To provide DOGGR and other applicable regulatory agencies with information which may be nec- essary to efficiently and effectively evaluate future permit applications for proposed oil and gas well stimulation practices, during or following well completion, in order to ensure a consistent approach to CEQA compliance. c. To identify and develop impact avoidance and mitigation strategies to address any significant environmental effects directly, indirectly or cumulatively resulting from well stimulation practices that are not already sufficiently addressed by the proposed regulations addressing well stimula- tion treatments to be adopted by DOGGR pursuant to PRC Section 3160, Subdivision (b)(1). d. To facilitate on-going coordination between DOGGR and other federal, State, regional and local agencies having regulatory authority over well stimulation practices. 3. Objectives of the Regulatory Process Mandated by SB 4 a. To ensure cooperation and communication among regulatory agencies to expressly regulate the practice of well stimulation through the imposition of certain standards, to require the collec- tion of data regarding well stimulation in California, and to require notification to those poten- tially affected by well stimulation practices. b. To prevent, as far as possible, damage to life, health, property, and natural resources resulting directly or indirectly from well stimulation, consistent with State statutes authorizing the effi- cient recovery of hydrocarbon resources, and consistent with impact avoidance and mitigation concepts of CEQA. Final EIR 7-2 June 2015 Analysis of Oil and Gas Well Stimulation Treatments in California 7. DESCRIPTION OF THE PROJECT c. To prevent damage to underground and surface waters suitable for irrigation or domestic pur- poses by the infiltration of, or the addition of, detrimental substances resulting directly or indi- rectly from well stimulation, consistent with State statutes authorizing the efficient recovery of hydrocarbon resources, and consistent with impact avoidance and mitigation concepts of CEQA. 7.3 Overview of the Lifecycle of an Oil and Gas Well As discussed in EIR Chapter 2 (Regulatory Framework for the Division of Oil, Gas and Geothermal Resources), DOGGR supervises the drilling, operation, maintenance and plugging and abandonment of oil, gas, and geothermal wells within California onshore and offshore within three nautical miles of the coastline, as mandated by the California Laws for Conservation of Petroleum and Gas (PRC Section 3000 et seq. [Division 3]) and California Code of Regulations Title 14, Division 2, Chapters 2 and 4 (Title 14). DOGGR’s general regulatory responsibilities are set forth under PRC Section 3106 of Division 3. This statute requires the Oil and Gas Supervisor to “so supervise the drilling, operation, maintenance, and abandonment of wells and the operation, maintenance, and removal or abandonment of tanks and facil- ities attendant to oil and gas production, including pipelines…so as to prevent, as far as possible, dam- age to life, health, property, and natural resources; damage to underground oil and gas deposits from infiltrating water and other causes; loss of oil, gas, or reservoir energy, and damage to underground and surface waters suitable for irrigation or domestic purposes by the infiltration of, or the addition of, detrimental substances” (Section 3106(a)). At the same time, however, Section 3106 also sets forth general