(parts of Los Angeles, Orange, San Bernardino, and Riverside Counties)
Before issuing building or grading permits, local permitting agencies review and implement the Division’s preconstruction well requirements. Interaction between local permitting agencies and the Division helps resolve land-use issues and allows for responsible development in oil and gas fields.
Frequently Asked Questions from Homeowners and Developers regarding the Division’s Construction Site Review Program.
The Division’s Construction-Site Plan Review Program consists of the following:
Procedures for Plugging and Abandonment or Reabandonment of Construction-Site Wells
A. The applicant (developer/landowner) presents a construction-site plan to the local permitting agency.
B. The local permitting agency checks the construction-site plan against Division maps to determine if any wells are located within or adjacent to the indicated property boundaries. If a well appears to be located within this area, the applicant is directed by the local permitting agency to provide materials specified by the Construction-Site Plan Review Program to the Division to initiate the review process.
C. The applicant provides the Division with the pertinent information and the district office provides the applicant with the well-location and elevation information from well records.
D. With the provided well location(s), the applicant must locate, uncover, and, when necessary, survey the well(s). If a well cannot be located using a well-record location description, sufficient efforts, including excavation, must be made to ascertain each well’s location within the construction-site boundaries.
E. The following procedures should be used to locate all wells within the construction site:
1. The applicant must attempt to locate a well using the location of record and dig an excavation that is at least 15 feet long, 15 feet wide, and 6 feet deep, or sufficiently larger or deeper as necessary. The applicant shall notify the Division to witness all completed excavations before they are back filled.
2. If the well is not located in Step 1, a magnetometer should be used to survey the area inside and outside of the excavation.
3. The applicant may be required to further excavate locations with magnetic anomalies by increasing the size of the excavation or using a more specialized geophysical survey.
4. If the well search efforts prove unsuccessful, the applicant must prepare a written report describing the search procedures and attach the excavation photographs.
F. All accessible abandoned wells located on a construction site must be tested for gas leakage and inspected for oil leakage. Any welded steel plates must be removed, and the presence of a competent cement plug must be verified in the casing and all annular spaces.
G. In the event that work is required on any well, including but not limited to plugging and abandonment, reabandonment, cutting off casing, or adding a riser, written permission is needed from the Division.
H. All conductors must be plugged with cement and leak tested by a Division inspector.
I. The top of the outermost casing stub of all wells within the construction site should be maintained within 5 to 10 feet below the surface of the final grade. The casing can be cut off or a riser added to achieve the required depth.
ALL WELL WORK MUST BE COMPLETED BEFORE ANY CONSTRUCTION-SITE PLAN APPROVAL IS ISSUED.
Construction-Site Plan Requirements
To conduct a review, the Division requires three copies of the plan along with a completed Construction-Site Review Application (PDF) that must be submitted to the appropriate Division district office.
Following well-location verification and testing, the applicant must correctly plot the well location on the construction-site plan map. Each well must be identified with the official name of the company/operator and the well designation. Wells in proximity, but outside the construction site, should also be plotted to verify their locations.
The construction-site plan should indicate the property and/or construction site boundaries, footprints of proposed structures, and existing structures that will remain. Also, existing and proposed oilfield facilities (tanks, processing equipment, enclosures, pipelines, etc.) that will be operating on the site after completion of the proposed development should be included.
The applicant should include a description of the existing type and height of all facility enclosures (e.g., fencing) and list any modifications that are part of the construction project.
Any conductor casing found on the site must be plotted on the construction-site plan and listed on the Construction-Site Plan Review.
Conducting Gas Tests on Wells
The Division requires that all accessible wells be located and tested for gas and/or oil leakage. Division staff conducts the test using the following guidelines:
1. Standing Water Test: Cement that is flush with the top of the casing is chipped down so that water poured on top is allowed to pool. This test consists of observing any bubbling through standing water in the casing and annular spaces. If bubbling is noted, the source of the bubbling must be ascertained. If the bubbling is from air displaced from micro fractures in the cement, the bubbling will cease within a short time.
2. Soap Test: A soap solution is sprayed on all exposed portions of the wellhead. Any bubbling is tested for combustible gasses with a sensitive testing instrument.
3. Bag Test: This test involves attaching a plastic bag over the casing and testing the vapor in the bag with a sensitive testing instrument. This method can be used in an empty annulus prior to approving a surface pour.
If there is any indication of oil or gas leakage, or if the surface plug does not have competent cement in the casing and/or annular spaces, the well needs to be reabandoned.
Obtaining a Permit to Work on a Well
If any well requires plugging work or extending or cutting casing, and that well has been previously plugged and abandoned, the applicant must file a Supplementary Notice (to Abandon) (Form OG123R) (PDF) with the appropriate district office. If the well has not been previously plugged and abandoned, then a Notice of Intention to Abandon (Form OG108) (PDF) must be filed with the appropriate district office. When the well work is completed, a Report of Operations (Form OG109) will be issued.
What Will You Receive From Us?
Once all the required well work is completed and all records are submitted, a Report of Well Abandonment (Form OG159) or Reabandonment (modified Form OG159) will be sent to you. This report states that all of the requirements have been fulfilled relative to plugging and abandoning or reabandoning the well, removing well equipment and junk, and filing well records.
In the event a well cannot be plugged to present-day standards or the equivalent, a modified Report of Well Abandonment or Reabandonment (Form OG159) will be prepared stating that the Division does not recommend that a building be constructed over the well without further consideration. On the Construction-Site Plan Review, further consideration may be satisfied with additional reabandonment requirements, and/or a recommendation of mitigation measures (e.g., vent system, impermeable membrane, passive collection system, etc.). On some occasions, the Division will recommend that no building be constructed over the well.
A Division engineer may prepare a Construction-Site Plan Review (Form OG190), which may include requirements and recommendations regarding surface mitigation for natural gas and any active wells and facilities that will remain after the development is completed.
When the review process is complete, the reviewing engineer may affix a Division certification or review stamp to all three copies of the Construction-Site Plan and all three copies of the Plan Review (Form OG190). One copy is sent to the local permitting agency, one copy is sent to the applicant, and the third copy is retained in the district office.
The Construction-Site Plan Review may have an expiration date of one year from the date of the review at the discretion of the District Deputy or local permitting agency.
If an applicant does not comply with the Division’s reabandonment requirements, which may be modified at local jurisdiction direction, the District will notify the local permitting agency of the situation.
Contaminated Soil Found at a Construction Site
The Division will notify the local permitting agency if contaminated soil is found at a project site.
1. When contaminated soil is discovered either by the applicant or a Division inspector, the phrase “Contaminated soil was found in proximity to the well” may be used as a comment on the Construction-Site Plan Review.
2. When contaminated soil is discovered after the Division has issued a Construction-Site Plan Review letter, a follow-up letter may be sent to the local permitting agency.
3. If an unrecorded well is discovered during the construction process, the Division must be notified immediately. Plugging and abandonment or reabandonment requirements will be determined at that time.
Water Wells
When an oil- or natural-gas well has been converted to a water well, the following policies apply:
A. If a well was drilled for the purpose of exploring for oil and natural gas, and penetrated any oil or gas zone, or penetrated the base of fresh water, that well is considered to fall under the requirements of PRC Section 3208.1 and should be treated as such during the Construction-Site Plan Review.
Wells that were converted to water wells and subsequently abandoned by water-well abandonment methods should be plotted on the construction-site plan and tested for leakage, because they penetrated below the base of fresh water or into oil and gas zones.
B. Wells drilled as known water wells do not fall under the requirements of PRC Section 3208.1 and are outside of Division jurisdiction. The reason they should be on the construction-site plan and listed on the plan review is to avoid confusing them with an oil or gas well in the event that become a problem in the future. However, if a water well is in an area of known shallow gas, the Division may recommend a vent system for the well.
Vent Systems and other Gas-Mitigation Measures
The Division has no jurisdiction over the design, installation, or maintenance of vent systems or any other gas mitigation measures. The Division can, as a responsible agency, make recommendations for the installation of vent systems or other gas mitigation measures in certain situations such as:
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When a well is within 10 feet or under a proposed structure or within the guidelines/requirements of a local jurisdiction.
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If a well is within 50 feet of a proposed structure and under a hardscape (e.g., cement or asphalt) improvement that leads directly to the proposed structure.
NOTE: Several options are available to help prevent leakage of gas into a structure. One option is to install a vent system. Click here for a list of vent contractors (PDF). A second option is to add surface mitigation such as an impermeable membrane, or add a passive collection system. A third option is to maintain a minimum 3-foot wide landscaped area between the well and the proposed structure.
The local permitting agency has the jurisdiction for requiring and approving vent systems. However, the Division may require that if a vent system or gas mitigation measure is installed, then records concerning the vent system or gas mitigation measures must be submitted to the Division.
Contact
District 1
Mel Saw - Orange and Riverside Counties
(714) 816-7824
Grace Brandt - Los Angeles and San Bernardino Counties
(714) 816-7822