Thus, in calculating withdrawal capacity at Aliso Canyon after May 10, 2016, the Joint Parties believe withdrawal capacity should be calculated based on tubing only. The Joint Parties note, however, that SoCalGas based its analysis on the assumption of tubing and casing. According to Joint Parties, data provided in response to SCGC-02, Q.2.3 for a portion of the wells demonstrates that the average of the verified tubing-only withdrawal rate is about 68% of the average of the traditional casing and tubing withdrawal rate. Joint Parties’ witness Yap calculated Aliso Canyon withdrawal as a percentage of the 1.86/d maximum withdrawal capacity at Aliso Canyon from October 23, 2015 through June 23, 2017. Yap reduced the withdrawal rate projected by SoCalGas on a casing and tubing flow basis to the high end of the Energy Division range (i.e., 80% of the tubing and casing withdrawals) to represent tubing-only flow. The Joint Parties thus calculate that a 300 MMcf/d withdrawal rate would result in only 16.1% of capacity (assuming 1.86 Bcfd). The Joint Parties also calculate that the withdrawal rate would still only be 20% of capacity (assuming the 1.5 Bcf/d advocated by SoCalGas). The Joint Parties argue that under either of these assumptions, withdrawal capacity was below the 25% minimum set in D.07-09-021, thereby defining Aliso Canyon as being out of service. Under D.07-09-021, the Joint Parties emphasize, a gas storage field is out of service if the mechanical equipment used either to inject or to withdraw gas at the rate of at least 25% of the capacity of the equipment is not available. Under D.0709-021, the cause of the out of service condition is irrelevant. The Joint Parties argue that SoCalGas has conflated the injection and withdrawal functions as a basis to argue that Aliso Canyon satisfied the capacity threshold test referenced in D.07-09-021.
Thus, in calculating withdrawal capacity at Aliso Canyon after May 10, 2016, the Joint Parties believe withdrawal capacity should be calculated based on tubing only. The Joint Parties note, however, that SoCalGas based its analysis on the assumption of tubing and casing. According to Joint Parties, data provided in response to SCGC-02, Q.2.3 for a portion of the wells demonstrates that the average of the verified tubing-only withdrawal rate is about 68% of the average of the traditional casing and tubing withdrawal rate. Joint Parties’ witness Yap calculated Aliso Canyon withdrawal as a percentage of the 1.86/d maximum withdrawal capacity at Aliso Canyon from October 23, 2015 through June 23, 2017. Yap reduced the withdrawal rate projected by SoCalGas on a casing and tubing flow basis to the high end of the Energy Division range (i.e., 80% of the tubing and casing withdrawals) to represent tubing-only flow. The Joint Parties thus calculate that a 300 MMcf/d withdrawal rate would result in only 16.1% of capacity (assuming 1.86 Bcfd). The Joint Parties also calculate that the withdrawal rate would still only be 20% of capacity (assuming the 1.5 Bcf/d advocated by SoCalGas). The Joint Parties argue that under either of these assumptions, withdrawal capacity was below the 25% minimum set in D.07-09-021, thereby defining Aliso Canyon as being out of service. Under D.07-09-021, the Joint Parties emphasize, a gas storage field is out of service if the mechanical equipment used either to inject or to withdraw gas at the rate of at least 25% of the capacity of the equipment is not available. Under D.0709-021, the cause of the out of service condition is irrelevant. The Joint Parties argue that SoCalGas has conflated the injection and withdrawal functions as a basis to argue that Aliso Canyon satisfied the capacity threshold test referenced in D.07-09-021.
231092904.docx