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[Exempt From Filing Fee


Government Code 6103]
i MARY C. WICKIIAM (State Baz No. 145664)
LAWRENCE L. HAFETZ (State Baz No. 143326)
2 SCOTT KUHN (State Bar No. 190517)
OFFICE OF THE COUNTY COUNSEL CONFORMED ~Ot~Y
3 648 Hali Administration ORIGINAL FILED
Suparior Court of Calffomfa
500 West Temple Street, 6th Floor County of Los Angeles
4 1 Los Angeles, California 90012
Telephone: (213)974-1882 MAR 0 8 2~1~
5
Sherri A. Ca tee, cz ~~' ~unicer/Clerk
LOUIS R. MILLER (State Bar No. 54141)
6 MIRA HASHMALL (State Baz No.216842) By:~._~~~~;~.Deputy
AMNON SIEGEL (State Bar No. 234981) ~7osaa Soto
7 asiegel@millerbazondess.com
MILLER BARONDESS,LLP
8 1999 Avenue ofthe Stars, Suite 1000 o ~~
Los Angeles, California 90067
9 Telephone: (310)552-4400 ~ ~~%~ ~.
]0 Attorneys for Petitioner ~ ~~
THE COUNTY OF LOS ANGELES ~~f~ L ~
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12 SUPERIOR COURT OF THE STATE OF CALIFORNIA
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V Q 13 COUNTY OF LOS ANGELES,CENTRAL DISTRICT
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15 ~ THE COUNTY OF LOS ANGELES, ~ ~
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~ 6 ~ N 16 Petitioner, PETITION FOR WRIT OF MANDATE
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(CCP 1085 or CCP 1094.5) AND
H 17 v. COMPLAINT FOR DECLARATORY
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RELIEF; REQUEST FOR INTERIM
18 CALIFORNIA DEPARTMENT OF STAY
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CONSERVATION,DIVISION OF OIL,
19 GAS, AND GEOTHERMAL RESOURCES;
KENNETH HARRIS IN HIS OFFICIAL
20 CAPACITY AS STATE OIL &GAS
SUPERVISOR,
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Respondents.
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SOUTHERN CALIFORNIA GAS
23 COMPANY,

24 Real ParCy in Interest


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333539.13

PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF


1 TABLE OF CONTENTS
Page
2 INTRODUCTION......................................................................................... 3

3 NATURE OF THE ACTION........................................................................... 3


4 PARTIES,JURISDICTION AND VENUE......................................................... 5
5 FACTUAL ALLEGATIONS........................................................................... 6
6 A. The Aliso Canyon Gas Storage Field................................................. 6
7 B. Natural Gas Has Significant Environmental Impacts.............................. 7
8 C. The Largest Natural Gas Leak In U.S. History Occurred At Aliso Canyon... 8

9 D. State Agencies And The Governor Respond To The Leak........................ 9


10 E. The Legislature Continues The Prohibition On Reinjecting Gas At Aliso
Canyon..................................................................................... 9
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F. The Root-Cause Analysis Is An Integral Part Of The Safety Review;
12 Injection Should Not Be Approved Until After It Is Completed................ 10
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Q 13 G. Injections Should Not Be Approved Until After SoCalGas Prepares, And
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DOGGR Approves, An Adequate Risk Management Plan.......................... 12

Z ~ o LL H. Respondents Identify,But Fail To Address,Seismic Risks........................ 13


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a e
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~ < p 16 SB380........................................................................................ 18
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~ 17 J. The County Submits Comments In Response To DOGGR's
January 17,2017 Letter................................................................... 19
18
P K. DOGGR Refuses To Produce An Environmental Impact Report
19 Under CEQA................................................................................ 20

20 L. DOGGR's Response To The County's Public Records Act Request.............. 22


21 FIRST CAUSE OF ACTION (Writ of Mandate)..................................................... 22

22 SECOND CAUSE OF ACTION (Declaratory ReliefCode of Civil Procedure 1060)...... 25

23 A. SB 380........................................................................................ 25
24 B. California Environmental Quality Act)............................................... 26
25 PRAYER FOR RELIEF.................................................................................... 27

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333539.13 2
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
The County of Los Angeles(the "County") petitions this Court for a writ of mandate
2 directing the named Respondents to comply with their obligations under State law and to do so

I before authorizing the injection of natural gas into the Aliso Canyon underground gas storage
facility. The County alleges, as follows:

This Petition is being filed to require Respondentsa regulatory agency of the


State of California and its Supervisorto perform theirjobs pursuant to, and as required by,
California laws enacted to protect the residents of Los Angeles County, and the Porter Ranch
community in particular, from another catastrophic leak at the Aliso Canyon gas storage facility;
]0 and to protect the environment ofthis State from further harm and degradation.
11 NATURE OF THE ACTION
12' For neazly four months between October 2015 and February 2016, the Aliso
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13 Canyon natural gas storage facility (the "Aliso Canyon facility") leaked over 100,000 metric tons
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m 14 of hazardous nahua] gas into the surrounding community. This was the lazgest natural gas leak in
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~ < 16 The Governor and the Division of Oil, Gas, and Geothermal Resources
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17 ("DOGGR")ordered a moratorium on injections of natural gas into Aliso Canyon. The County
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19 mandating Southern California Gas Company("SoCalGas")to abate the gas leak and relocate
20 affected residents. Thousands of residents were relocated to temporary housing for months.

21 4. On May IQ 2016, the California Legislature enacted Senate Bill No. 380
22 ("SB 380"),codified in relevant part at Public Resources Code section 3217, directing

23 Respondents to continue the prohibition on injection of natural gas until Respondents conduct a

24 comprehensive safety review of the entire facility, address the risks of failure identified in that

25 review, and satisfy their duty to prevent damage to life, health and property.

26 5. Because the massive gas leak caused substantial hann to residents and the
27 environment, SB 380 required the California Public Utilities Commission("PUC")to conduct an

28 investigation into minimizing or eliminating the use of the Aliso Canyon facility.

333539.13 3
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY REL[EF
6. Respondents and the public still do not know the cause of the leak over 16 months
after it began. Respondents ordered an independent, third-party investigation into the root cause
ofthe leak more than one year ago, but this root-cause analysis is still ongoing and will not be

completed until later this year, at the earliest.


7. The root-cause analysis is central to the comprehensive safety review ordered by
the Governor and the Legislahue. Withoutknowing the cause of the leak, Respondents cannot
know if it is safe to pump natural gas at high pressure into the facility.

8. Despite the risk of another disastrous leak, Respondents intend to authorize


reinjections of gas at high pressure into the Aliso Canyon facility without complying with their
10 legislatively mandated duties. They have not completed the comprehensive safety review required
I1 by SB 380, have not addressed the risks of failure at Aliso Canyon and have not completed the
12 root-cause analysis.
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13 9. After the leak, Respondents ordered SoCalGas to provide a risk management plan
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t o IS natural gas into the Aliso Canyon facility. Yet, Respondents have backtracked on this requirement
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17 emergency response plan.
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18 10. Earthquakes are one of the major risks of well failure that Respondents have
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19 identified but not addressed. The Aliso Canyon facility transects the Santa Susana Fault and lies in
20 a region with awell-known risk ofsignificant seismic activity. Respondents and SoCalGas

21 acknowledge that there is a high probability of a big earthquake (magnitude 6.3 or greater) in the

22 Aliso Canyon area in the next 50 yeazs.


23 1 1. Yet, Respondents have not adequately analyzed or addressed this seismic risk.
24 Instead, Respondents identified or acknowledged the risk but have stated that necessary seismic

25 testing can be done later; and they concluded their comprehensive review without addressing the

26 full extent of the risk.


27 12. The people living near this facility should not have to live in fear of another major
28 catastrophe. An earthquake could cause multiple well blowouts that would dwarf the earlier

333539.13 4
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
massive leak and cause even greater human suffering, harm and hardship.
13. Nor have Respondents done an environmental impact analysis as required by
another California lawthe California Environmental Quality Act("CEQA"). Respondents
should not approve gas injection at the Aliso Canyon facility until Respondents comply with

CEQA,along-standing California law designed to identify environmental impacts and risks and to
protect and preserve the environment.
14. This Petition is necessary to ensure that Respondents fulfill their legal obligation to
protect life, health and property, and to ensure that no damage occurs to the environment by reason
ofinjection and withdrawal of natural gas. To do so, Respondents should be ordered not to
ILI] approve injection of natural gas into the Aliso Canyon facility until all ofthe risks offailure aze

identified and addressed, pursuant to the laws of this State, and before the CEQA legal
12' requirements aze met.
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V p 13 PARTIES JURISDICTION AND VENUE
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~^ 14 15. Petitioner County of Los Angeles is a chartered county of California. It has a
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15 primary stake in Respondents' decision to authorize the injection of natural gas into the
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17 responder, and public health agency, with respect to any disaster that occurs within its boundaries.

18 In response to this leak, the County expended millions of dollars. The County Fire Department
19 immediately responded to the leak and was a key component of central command addressing the
20 leak and the risks associated with the massive spewing of natural gas. The County Deparhnent of

21 Public Health ("DPH"), which also serves as Los Angeles City's health department, responded

22 immediately and aggressively to address public health problems caused by the leak. Among other
23 things, DPH ordered SoCalGas to provide relocation services to impacted residents; conducted a

24 community-wide health assessment; oversaw comprehensive environmental testing protocols; and


25 tracked and responded to hundreds of resident health complaints. In addition, the County

26 Department of Consumer and Business Affairs handled numerous resident reimbursement disputes

~/ and helped residents obtain payment for reimbursements they were owed from SoCalGas.

Therefore, the County has a concrete and particularized injury when an underground gas storage

333539.13 5
PETITION POR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
facility, like Aliso Canyon, suffers a failure.

16. Moreover, the County has an obligation to protect its residents. The County can
seek this mandamus reliefto protect the public interest and ensure that Respondents--other
governmental agenciescomply with the law and prevent damage to life, health and property of
County residents.

17. Respondent DOGGR is a division of the State of California's Department of


Conservation.

18. Respondent Kenneth Harris is the State Oil and Gas Supervisor at DOGGR.
19. Real party in interest SoCa1Gas is a public utility company organized under the
10 laws of the State of California. SoCalGas is a natural gas distribution utility that stores, sells and
1 1 transmits natural gas in California and is the operator of the Aliso Canyon facility. SoCalGas's
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12 principal place of business is in Los Angeles County.
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~~ 20. This Court possesses jurisdiction pursuant to Code of Civil Procedure
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18 23. Pursuant to Public Resources Code section 21167.5, notice of the County's intent to
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- 19 file this petition was provided to Respondents.


20 24. Pursuant to Public Resources Code section 21167.7 and Code of Civil Procedure
21 section 388, a copy of this petition is being served on the California Attorney General.
22 FACTUAL ALLEGATIONS
23 A. The Aliso Canyon Gas Storaee Field
24 25. The Aliso Canyon facility is located in the San Fernando Valley in Los Angeles
25 County. The facility is approximately 24 miles from downtown Los Angeles in the residential

26 community of Porter Ranch. Over 30,000 people live in Porter Ranch.

27 26. SoCa1Gas purchased the Aliso Canyon facility in 197E It previously had been a
28 iepleted oil field. SoCa1Gas converted Aliso Canyon into an underground natural gas storage

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PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
facility, but continued to use the old oil wells for pressurized gas injection and withdrawal.

27. Prior to the leak, the Aliso Canyon facility was the lazgest of the natural gas storage

facilities owned by SoCalGas. The facility consists of 115 wells and has a capacity of 86.2 billion

cubic feet of natural gas.

28. The wells consist of an assembly of valves, flanges and caps above ground, and an

6 inner metal pipe and outer concrete casing thousands offeet underground, often over a mile deep.

7 Natural gas is compressed to very high pressure and injected underground into a reservoir

8 comprised of porous oil sands and rocks. SoCalGas's wells have an average age of52 years;

9 some date back more than 80 yeazs; well depths often exceed 8,000 feet underground.

10 29. These wells aze plagued with corrosion, structural integrity problems, erosion and

11 other safety hazards. Indeed, SoCa]Gas has acknowledged that the gas wells throughout its

12 Los Angeles County storage fields pose "safety and environmental risks" because critical well
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1/ B. Natural Gas Has Sienificant Environmental Impacts
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18 31. The main ingredient in natural gas is methane(94%),a potent greenhouse gas. In

19 addition, natural gas contains hazazdous pollutants such as benzene (a known carcinogen and

20 reproductive toxin), toluene(a reproductive toxin), and ethylbenzene(a carcinogen). Natural gas

21 also includes other chemicals including tert-butyl mercaptan and tetrahydrothiophene, which give

22 methane its rotten-egg smell.

23 32. Short-term exposure to tert-butyl mercaptan can cause adverse health effects such

24 as headaches, dizziness, nausea, vomiting, pulmonary irritation, expiratory wheezing, rapid

25 heartbeat, and irritation of the eyes, skin and mucus membranes. Short-term exposure to

26 tetrahydrothiophene can cause similar adverse health effects. (Tert-butyl mercaptan and

27' tetrahydrothiophene are referred to together herein as "mercaptan.")

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333539.13 ~
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
33. The long-term effects of exposure to these chemicals are unknown, because a leak
2 II of this magnitude (over 100,000 metric tons) has never occurred before in this country.

34. Natural gas is highly flammable and easily ignited by heat or sparks. Vapors
caused by a natural gas leak can form an explosive mixture with air; vapors can also cause
dizziness or asphyxiation without warning. Because nahual gas is lighter than air, it can migrate
into enclosed spaces.

C. The Lareest Natural Gas Leak In U.S. History Occurred At Aliso Canvon
35. On October 23, 2015, a natural gas leak was discovered at well SS-25 at the
9 Aliso Canyon facility. It took neazly four months to stop the leak.
10 36. On February 18, 2016, state officials announced that the leak had finally been
1 1 . plugged. It is estimated that more than 100,000 metric tons of methane were released into the
12 environment as a result of the Aliso Canyon leak, making the incident the largest natural gas leak
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14 addition to methane, 7,300 tons of ethane were also released. Those amounts aze equal to 24% of
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17 atmosphere 84 times that ofcarbon dioxide. During the four months the leak lasted-25 days

18 longer than the BP oil spill in the Gulf ofMexicothe leak contributed roughly the same amount
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19 of wanning as the greenhouse-gas emissions produced by the entire country of Lebanon.


20 38. The leak was initially described by SoCalGas as a "minor problem" at the well
21 head. This was false. There was a hole in the well casing about 480 feet down that leads to a deep

22 underground, highly-pressurized reservoir over 8,000 feet below the surface.


23 39. SS-25 had been equipped with a safety shut-off valvelocated underground at the
24 base ofthe pipe, well below where the leak occurred. But in 1979, the sub-surface safety valve

25 was damaged, and SoCalGas decided not to repair or replace it. Instead, to avoid incurring the
26 expenditure of approximately $50,000 to repair ar replace the broken valve, SoCalGas knowingly

27 and intentionally failed to repair or replace the safety valve and left the well vulnerable to the

28 catastrophic leak that occurred.

333539.13 8
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
40. Respondent DOGGRthe State regulator charged with preventing harm to life,
2 health, property and the environmentknew,but did nothing, about the broken safety valve; and

DOGGR has failed and refused to require SoCalGas to install sub-surface safety valves despite

knowing that, if installed, the safety valve could have prevented the calamity that occurred at

Aliso Canyon.

D. State Aeencies And The Governor Resaond To The Leak

7 41. After SoCa1Gas disclosed the leak, DOGGR and the PUC both opened

8 investigations to determine the root cause of the leak. The State regulators also agreed to review

9 the well file and project data of SS-25, to determine the contributing factors ofthe leak.

10 42. On December 10, 2015, DOGGR issued an emergency order, Order No. 1106,

11 prohibiting the injection of natural gas into the Aliso Canyon facility until DOGGR provides

12 authorization. DOGGR acknowledged that the uncontrolled leak from well SS-25 called into
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13 question the integrity and safety of all of the wells at the Alison Canyon facility.
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~6 16 gas into the Aliso Canyon facility until "a comprehensive review, utilizing independent experts, of
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17 the safety ofthe storage wells and the air quality of the surrounding community is completed."
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18 44. In the emergency proclamation, the Governor recognized that DOGGR and the
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19 PUC had already "instituted investigations of[the] natural gas leak and ordered an independent,

20 third-party analysis of the cause of the leak" and further ordered that DOGGR undertake a more

21 "comprehensive" review before authorizing reinjections.

22 E. The Leeislature Continues The Prohibition On Reiniectine Gas At Aliso Canyon

23 45. Following the leak, the California Legislature enacted Senate Bill No. 380.
24 SB 380, codified in section 3217(a)(1) ofthe Public Resources Code, directs Respondents to

25 continue the prohibition against SoCalGas injecting any natural gas into the Aliso Canyon facility

26 until: (1)"a comprehensive review of the safety of the gas storage wells at the facility is

27 completed and the supervisor determines that well integrity has been ensured by the review";

28 (2)"the risks of failures identified in the review have been addressed"; and (3)"the supervisor's

333539.13 9
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
duty to prevent damage to life, health, property, and natural resources, and other requirements, as

2 ~ specified in Section 3106,is satisfied."

46. As part of the "comprehensive safety review," Respondents aze required to test and

~ inspect all gas storage wells at the Aliso Canyon facility and determine whether each well must be

plugged and isolated, or whether the well can safely be returned to service.

D 47. In addition, SB 380 directs the PUC to investigate whether it is feasible to

minimize or eliminate the use of the Aliso Canyon facility while still maintaining energy

reliability for the region.

48. The moratorium on injections at Aliso Canyon has been in place for over a year.

10 SoCalGas claimed that without Aliso Canyon,there would be blackouts and brownouts in the Los

11 Angeles basin due to insufficient energy supply. This has not occurred. During the prohibition on

12 injection, Aliso Canyon has not been needed in the last yeaz and a half.
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m 14 the need for gas from Aliso Canyon. There is no need to authorize new injection of gas at high
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17 F. The Root-Cause Analysis Is An Integral Part Of The Safety Review; Infection Should

18 Not Be Approved Until After ItIs Completed

19 50. The Governor in his proclamation, and the Legislature in SB 380, instructed

20 ~ Respondents not to approve reinjection until a comprehensive safety review is complete.

21 51. The root-cause analysis is a core component of the comprehensive safety review.

22 The root-cause analysis will determine the cause of the blowout of well SS-25, the contributing

23 factors to the failure and how to prevent its recurrence.

24 52. On February 9, 2017, Ken Bruno of the PUC's Safety and Enforcement Division

25 provided testimony at a hearing of the California Senate Committee on Natural Resources on SB

26 57 in which he stated that aroot-cause analysis is necessary Yo provide the "ultimate level of safety

27 to really understand what happened and that barriers are in place to prevent a recurrence."

28 Mr. Bruno explained in this testimony that as part of the root-cause analysis, the "lazger field at

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PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
Aliso [Canyon] is also in play because we aze looking at patterns" and "the other wells at Aliso are
2 part of the investigation."

53. The root-cause analysis is estimated to conclude some time later this year. Yet,
DOGGR Supervisor Harris sent a letter to SoCa1Gas on January 17, 2017, stating that "the gas
storage well comprehensive safety review is complete." Supervisor Harris did not mention the
root-cause analysis in his letter.

54. SB 380 requires a "comprehensive" review of the safety of the gas storage wells at
the Aliso Canyon facility. Respondents cannot know the risks presented by the Aliso Canyon
facility without knowing the root cause of the leak, the circumstances which led to the teak and
10 whether there are similar problems in the other aging wells at the facility.
1] 55. Respondents' decision to conclude their safety review without waiting for the root-
12' cause analysis fails to comply with their mandate under SB 380.
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13 56. DOGGR's decision to proceed is also troubling in light of DOGGR's own recent
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l~ this Report, DOGGR acknowledged that it had improperly approved permits to operate injection
18 wells, maintained poor recordkeeping, lacked sufficient numbers of trained personnel, and failed
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19 to comply with reporting obligations.

20 58. Specifically, in this Report, DOGGR admitted that 78% of underground injection
21 projects in the central and southern portions of Los Angeles County did not include all the safety
22 and operational documents required to be filed by oil and gas companies for injection well
23 projects. There were "missing well lists, missing well casing diagrams, casing diagrams with

24 insufficient data such as the location ofthe top of the injection zone, specific [underground source

25 of drinking water] USDW depths, or reference to a USDW,and well histories with inconsistent

26 information." Compounding the problems, there had not been a proper determination of the

27 appropriate pressure for injection.

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PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
59. Also, per the DOGGR Report, an analysis was performed to determine the cause of

the DOGGR's "systematic problems." The causes attributed to DOGGR's problems are, as

3 follows:

4 a. insufficient staffing to address increasing regulatory workload in addition to


5 significant remedial programmatic work;
6 b. poor recordkeeping on mostly paper forms and the lack of modern data
7 tools and systems;

c. outdated regulations that in some cases do not address the modern oil and

gas extraction environment;


10' d. inconsistent and undersized program leadership;
it e. insufficient breadth and depth of technical talent;
12 f. insufficient coordination among field districts and Sacramento; and
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18 withholding documents from the public despite the mandate for disclosure in SB 380.
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19 G. Iniectio~s Should Not Be Aparoved Until After SoCalGas Prepares, And DOGGR
20 Approves, An Adequate Risk Manaeement Plan

21 62. A risk management plan is an essential component of addressing the risks of the
22 safety review. On March 4, 2016, DOGGR issued Emergency Order No. 1109 directing

23 SoCalGas to take certain actions to demonstrate the integrity and safety ofeach of the wells in the

24 Aliso Canyon facility before Respondents authorize reinjections. Respondents established

25 conditions that SoCalGas must comply with before Respondents approve injection. One of those

26 conditions was for SoCalGas to complete a risk management plan that includes afacility-wide

27 emergency response plan and effective geologic and geotechnical hazard mitigation protocols.

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PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
63. But DOGGR has failed to comply with these mandates, both of which are required
before SoCalGas can even request authorization from Respondents for injection.

64. A risk management and emergency response plan is critical to ensure that damage
to life and property as a result of a catastrophic incident is addressed.

65. Respondents acknowledged that "risk management planning for underground gas
storage facilities is a new and complex requirement." Respondents recognized the "need for in

depth and technical discussions" with natural gas storage operators regarding any initial
submissions and that those submissions would "likely lead[] to further developments of these
plans."
10' 66. SoCalGas provided Respondents with an "initial submission" of its risk
I l management plan in September 2016. The initial submission is not specific to Aliso Canyon, but
12 applies to all of SoCalGas's gas storage facilities.
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13 67. After SoCalGas made its "initial submission," Respondents acknowledged [he need
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1~ and inadequate, and yet are primed to approve natural gas injection into the Aliso Canyon facility.
18 Injection should not occur until there is an effective and final risk management plan, as legally

19 required.
20 69. In addition, injection should not occur until SoCalGas updates its emergency
21 response plan. Crucial components of SoCalGas's current emergency response plan have not been
22 updated since the leak.

23 H. Respondents Ideatifv, But Fail To Address,Seismic Risks


24 70. The San Fernando Valley is parCiculazly prone to seismic activity. In 1971, the
25 region suffered an earthquake that had a magnitude of6.7. This earthquake, dubbed the

26 "San Fernando Earthquake," caused 64 deaths, injured more than 2,500 people and caused more

27 than $500 million in property damage.

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PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
i 71. In 1994, the region suffered another major earthquake with a magnitude of 6.7.
2 This earthquake, dubbed the "Northridge Earthquake," killed 60 people, injured more than 9,000
3 others and caused over $20 billion in property damage. The Northridge Earthquake occurred on a
4 previously undiscovered fault now named the Northridge Blind Thrust Fault. The earthquake was
5 so severe that it caused well.SS-40 at Aliso Canyon to collapse even though the earthquake did not
6 rupture the Santa Susana Fault Line which runs under Aliso Canyon.
7 72. Throughout recent history, the U.S. Geological Survey has reported earthquake

Q damage to other oil and gas wells in Southern California:


9 a. In 1941, 15 wells were damaged at Dominguez oil field from a 4.9
10 magnitude earthquake.
ll b. In 1944, 16 wells were damaged sub-surface by a 4.5 earthquake.
12 a In 1949, 200 wells in the Wilmington oil field were damaged when a fault
0
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y 13 slipped less than one foot and tore the casing apart. A major earthquake
h ~~
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m ~;
~ 6 16 e. In 1961, a 3.5 magnitude earthquake damaged 150 wells in Wilmington.

~ ~ : 17 f. In 1963, three wells were damaged in Inglewood from a 3.4 magnitude


18 earthquake.
19 g. In 1971, several wells in the San Fernando oil field were damaged from an
20 earthquake.
21 h. In 1983, 14 wells failed by casing collapse and shearing due to shaking in
22 the Coalinga earthquake even though they were not in the epicenter.
23 73. Most of these earthquakes were smaller than the magnitude 6.3 or greater
24 earthquake expected to occur in the Aliso Canyon azea.
25 74. Natural gas well failures are even more dangerous than oil well failures. Natural
26 gas, unlike oil, is lighter than air and will migrate to the surface upon a well blowout. This is what

27 happened in the recent leak. Once natural gas escapes, it poses a very serious risk offire and
28 explosion.

333539.13
14
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
75. The risks offailure from seismic activity aze very real at Aliso Canyon.
Aliso Canyon and the Santa Susana Fault System experience frequent seismic activity. Since

2006, there have been over 100 earthquakes in Aliso Canyon, with 16 ranging from 2.0 to 4J in

magnitude. The Santa Susana Fault is directly below the Aliso Canyon gas storage field. Small

earthquakes are often precursors to lazger ones.

76. As the Northridge Earthquake shows,seismic activity poses serious risks to well

integrity. Major earthquakes, even when the storage field is not near the epicenter, can cause

wells to crack and even split in half. Minor earthquakes, and the landslides they cause, can

9~ damage wellheads, pipelines and related equipment.

10 77. Neither of the two major earthquakes that occurred in the region (1971 and 1994)
11 were on the fault line underneath Aliso Canyon. A magnitude 6.3 or greater earthquake on the

12 Santa Susana Fault would cause catastrophic well and reservoir failures at Aliso Canyon.
0
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17 mandated by the Governor and the Legislature and directed SoCalGas to provide information.
s
18 Similarly, SoCalGas acknowledged that "there aze geologic and geotechnical risks to operating
6

19 and maintaining a natural gas storage facility" that range "from seismic activity to landslides, and

ZO could damage SoCalGas's assets above and below ground:


'
21 79. SoCa1Gas further acknowledged that "localized landslides could pose a risk to the
22 wellhead, wellsite piping, withdrawal/injection piping, and process equipment through debris fall

23 induced through non-seismic events, such as heavy rain."

24 80. SoCalGas also acknowledged that according to seismic experts, there is a "high
25 probability that an earthquake larger than magnitude 6.3 will occur within 50 km of the

26 Aliso Canyon Field [) in the next 50 years."

27 81. SoCalGas told DOGGR that it "will undertake further study of the geologic and
28 geotechnical hazazds in the area to determine if other mitigation measures are warranted, and to

333539.13
15
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
determine if there aze ways to better understand the probability of these events." And SoCalGas
2 "acknowledge[d) the need to submit additional data and information as it works collaboratively
II
with DOGGR toward the final SRMP [Storage Risk Management Plan)."
4 82. Thus, despite SoCalGas's admission that the process of addressing seismic risks
has not been completed, DOGGR is primed to authorize injection.

83. DOGGR requested that specialists within the National Laboratory System
supported by the United States Department of Energy consider the seismic hazards and risks at the
Aliso Canyon faciliTy and review SoCa]Gas's risk management plan.
9 84. On December 12, 2016, specialists from the Lawrence Berkeley National
10 Laboratory, the Sandia National Laboratory and the Lawrence Livermore National Laboratory (the
1 1 "Laboratories") confirmed "that Aliso Canyon exists in an azea with a high probability for a
12 significant earthquake in the next 50 years. The extensive faulting of the region and the hazards at
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~
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w r
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~ ~~ i/ tests are conducted. An earthquake can lead to multiple well failures that will cause human and
0
18 environmental harm much greater than the recent 100,000 metric ton leak.

- 19 86. The Laboratories stated that the "risk assessment should incorporate the designs of
20 the wells being used at Aliso Canyon" and that "detailed structural analysis of the Aliso Canyon
21 wellbore designs incorporating the results [of seismic testing] will better inform the risk
22 management process for operation of Aliso Canyon." No analysis of the effect ofseismic activity
23 on the structural design of the wells at Aliso Canyon has been completed.
24 87. A Professor of Geology at California State University Northridge, Matthew
25 d'Alessio, has confirmed that Aliso Canyon is located directly above the Santa Susana fault. He

26 concluded that there is a 78%chance of a major earthquake neaz Aliso Canyon in the next

27 50 years.

28

333539.13
16
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
88. The Professor also concluded that fault slippage from such an earthquake could
2 slice the storage wells in half and that there are no mitigation measures in place to address such
catastrophic well failures. Professor d'Alessio opined that SoCalGas should complete its study
into the seismic risks to the Aliso Canyon facility before Respondents authorize natural gas
injection.

89. The seismic studies have not been done. The risk management plan, which applies
broadly to all SoCalGas facilities, does not address how to protect the welts at Aliso Canyon and
the neazby community in the event of a major earthquake. SoCalGas and DOGGR admit that the
Aliso Canyon risk management plan needs to be developed to address these seismic risks.
10 90. In sum,the risks of injecting gas at high pressure aY Aliso Canyon have not been
1 1 addressed, as required by SB 380. If this storage facility was located above ground, these risks
12 would have to be addressed before the facility began operations. Yet, DOGGR intends to
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17 seismic activity affecting the integrity ofthe Aliso Canyon facility. DOGGR cannot "kick the can

18 down the road" on seismic testing that has been identified as necessary and that the lawSB
19 380requires be "addressed" before approving injection at Aliso Canyon.
20 92. The Legislature, specifically SB 380, required that these risks be "addressed"
21 before the facility is reopened. This duty cannot be satisfied without creating an Aliso Canyon-

22 specific risk management plan incorporating earthquake dangers and an emergency response plan.
23 93. A massive earthquake in the region could destroy multiple wells simultaneously
24 and undermine the integrity of the entire underground storage facility. After the human and
25 environmental disaster that the recent single-well leak caused, the public should not have to

26 tolerate unaddressed risks from the potential of multiple well failures.

27

28

333539.13 1~
PETITION FOR WRIT OF MANDATE ANd COMPLAINT FOR DECLARATORY RELIEF
I. DOGGR Prematurely Ends Its Safety Review Without Comnlvin With SB 380
94. In a letter dated 7anuary 17, 20]7, Supervisor Harris stated that the "comprehensive
safety review is complete" and advised that DOGGR would schedule the public hearing required
by SB 380.

95. Respondents concluded the comprehensive safety review without receiving the
root-cause analysis, without receiving a final risk management plan and emergency response
program from SoCalGas, and without the necessary information and studies to address seismic

risks.
9 96. SB 380, codified at Public Resources Code section 3217, requires that the DOGGR
10 supervisor shall make a written finding that each ofthe 114 remaining gas storage wells at
11 Aliso Canyon has satisfactorily completed the testing and remediation required and provides that
12 the comprehensive safety review is not complete until every gas storage well at the facility has:
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17 Aliso Canyon well Porter 32 was still undergoing testing. The comprehensive safety review
18 required by SB 380 was therefore not complete as ofJanuary 17, 2017. Nor was it complete as of
6

19 February 6,2017. The public meetings held on February 1 and 2,2017 were premature and did

20 not comply with SB 380 because they were held prior to the completion of the comprehensive

21 safety review.
22 98. Similarly, DOGGR violated SB 380 by noticing the public meeting before all wells
23 had undergone necessary testing. At least one of the wells had not undergone testing when
24 DOGGR noticed the public meeting mandated under SB 380. This is a violation of SB 380's

25 requirement that the public meeting be held "[u]pon completion of the gas storage well

26 comprehensive safety review."

27 99. In its review, DOGGR determined that only 35 wellsless than 30%at
28 Aliso Canyon have passed inspection. The fact that only 35 out of 114 remaining wells passed

333539.13 18
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
inspection demonstrates that the Aliso Canyon facility was woefully unsafe prior to the leak.

100. On information and belief, DOGGR concluded the safety review under SB 380,

and approved 35 wells as passing that review, without reviewing the well files for each well. The

well files contain the historical performance ofthe wells and contain records of any failure or

impairment to well integrity. An analysis of the well files shows that there are unaddressed safety

issues with many of the 35 wells that require further investigation and analysis before the wells

7 can be used for injection. DOGGR has acknowledged the importance of reviewing the SS-25 well

file in determining the cause of the leak but has omitted the well files from its safety review of the

remaining 114 wells. DOGGR cannot bury its head in the sand and authorize injection into wells

10 without reviewing the historical issues and problems with those wells.

1 1 ' J. The County Submits Comments In Response To DOGGR's January 17 2017 Letter
12 101. On February 6,2017, the County provided a detailed comment letter to
0
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~
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O 3
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17 disastrous methane leak remain unknown because the root-cause analysis has not been completed.
a
18 DPH and the Fire Department both recommended that Respondents continue the moratorium on
6

19 natural gas injection until the root-cause analysis is completed.

20 103. Geology Professor d'Alessio also submitted comments to DOGGR,attached to the

21 County's comments, in which he explained the substantial risk offault slippage and tectonically

22 induced well damage from a magnitude 63 or greater earthquake. Professor d'Alessio

23 recommended that SoCalGas complete its study into the seismic risks to the Aliso Canyon facility

24 before Respondents authorize nahual gas injections. The County joined in Professor d'Alessio's

25 recommendation.

26 104. The County also advised Respondents of the failure to comply with their

27 obligations under SB 380 to, among other things: complete the comprehensive safety review on all

28 wells at Aliso Canyon before it held the public meeting; and to post safety review-related

333539.13
19
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
1 materials on the public portion of DOGGR's website in a timely manner, including:
2 a. SoCaIGas's emergency response plan submitted to DOGGR on
3 September 30, 2016;
4 b. DOGGR's October 5, 20161etter to SoCalGas regazding the risk
5 management plan;
6 c. the Final Failure Analysis prepazed for SoCalGas that was delivered to the
7 PUC on November 9, 2016;
8 d. DOGGR's January 17, 2017 letter discussing data gaps in SoCalGas's
9 project Sle;
10 e. the PUC's safety assurance inspection results;
11 f. the test results for well SS-25; and
12 g. the comment letter from the Fire Department dated Januazy 3, 2017.
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13 105. To date, the CounTy has received no response from DOGGR to its written
N 2 '^
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OS
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~ ro IS K. DOGGR Refuses To Produce An Environmental Impact Report Under CEOA
~ ~;
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17 "prepaze, or cause to be prepazed by contract, and certify the completion of, an environmental

~~ impact report on any project that they intend to carry out or approve which may have a significant
19 effect on the environment." Per the California courts, the environmental impact report("EIR")
20 required by section 21 I51 "is the heart of CEQA."
21 107. CEQA's purpose is to inform the public and its governmental officials of the
22 environmental consequences oftheir decisions before they are made. (Citizens ofGoleta Valley v.

23 Board ofSupervisors(1990)52 Cal. 3d 553, 563). "Thus, the EIR `protects not only the
24 environment but also informed self-government."'(Laurel Heights Improvement Assn. v. Regents

25 ofUniversity ofCalifornia (1988)47 Cal. 3d 376, 392).

26 108. The Legislature has declazed it the policy of the State to "consider alternatives to
27 proposed actions affecting the environment." (Pub. Resources Code, 21001 (g)). Pub.

28 Resources Code section 21002.1(a) provides: "The purpose of an environmental impact report is

333539.13 20
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
to identify the significant effects of a project on the environment, to identify alternatives to the
project, and to indicate the manner in which those significant effects can be mitigated or avoided."

109. There aze numerous alternatives available to maintain reliable natural gas supplies
in Southern California other than allowing new injection of gas into Aliso Canyon. The County's
February 6,2017 comments explained that the vazious mitigation measures implemented to reduce
nahual gas demand and reliability were working and should be expanded.
1 10. CF.:QA also requires DOGGR to mitigate or avoid the significant effects on the
environment of projects that it approves whenever it is feasible to do so. Tl~~ County's Febniary
6.2017 comments to DOGGR include the expert opinion of petroleum engineer Calvin Barnhill
l0 from Northstaz Exploration Company,a registered professional engineering company, explaining
1 1 that if a wellhead fails or is damaged where there is no secondary barrier to contain and prevent a
12~ gas leak, gas would escape uncontrollably into the atmosphere. In other words, the subsurface
0
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yj Z r
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17 mandated "no single point of failure" requirement. Subsurface safety valves are a feasible
s
18 mitigation measure that will mitigate or avoid the significant effect of a possible gas Leak due to
6

19 well-head failure. Geology Professor d'Alessio also recommends subsurface safety valves to

20 protect against well failure from seisinie aetiviCy.


21 1 12. As the Lead agency, DOGGR has the legal obligation and duty to comply with
22 CEQA and to prepare and certify an EIR before approving injection of natural gas into the Aliso
23 Canyon facility.

24 1 13. The County informed DOGGR of its CEQA obligations orally on February 1 and 2,
25 2017, and in writing on February 6, 2017. DOGGR refuses to aelrnowledge its CEQA obligations

26 and intends to approve injection without producing an EIR as required by California law.

27

28

333539.13 Z1
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
L. DOGGR's Response To The County's Public Records Act Request

1 14. On January 31,2017, the County served a Public Records Act(PRA)request on

DOGGR seeking documents related to the safety review, the root-cause analysis, seismic risks,

and other issues related to Aliso Canyon. In response, DOGGR stated that the County should not

expect a response from DOGGR for "at least six to eight months." After afollow-up letter from

the County, DOGGR produced some documents but stated that it will not produce documents

relating to the root-cause analysis investigation "in order to protect the integrity of the ongoing

root-cause analysis investigation and to avoid public confusion."

1 15. DOGGR is stonewalling the County and the public. The public is entitled to all

10 documents relating to the root-cause analysis now, before DOGGR authorizes injection into the

facility. The root-cause analysis is critical to determining the safety of the wells at Aliso Canyon.

12 Public interest militates in favor of providing all root-cause analysis documents to the public, not
0
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~ < 16 refusing to provide the County with root-cause analysis documents and other public records about
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17 the safety review and Aliso Canyon,DOGGR is violating the PRA and SB 380. DOGGR is

18 further violating its obligations under SB 380 (codified in Public Resources Code section 3217(j))

19 to make all safety review-related materials available to the public on its website.

20 FIRST CAUSE OF ACTION

21 (Writ of Mandate)

22 117. Petitioner incorporates by reference the foregoing pazagraphs of this Petition as if

23 set forth fully herein and further contends as follows.

24 1 18. Petitioner prays fora writ of mandate pursuant to Code of Civil Procedure section

25 1094.5, or, in the alternative, Code of Civil Procedure section 1085, directing Respondents to

26 I comply with their legal duties under SB 380 before approving reinjection of natural gas into the

27 Aliso Canyon facility.

28

333539.13 ZZ
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
119. The Legislature has directed Respondents to ensure that the injection of natural gas
into storage wells does not injure the public or damage the environment. Pursuant to Public

Resources Code section 3106(a), Respondents aze required to supervise the drilling, operation,
maintenance and abandonment of wells "so as to prevent, as far as possible, damage to life, health,
property, and natural resources." And pursuant to Public Resources Code section 3403.5(a),
Respondents must maintain surveillance over the Aliso Canyon facility to ensure "that no damage
occurs to the environment by reason ofinjection and withdrawal of gas." Respondents have not
complied with their legal obligations.

120. Pursuant to SB 380, codified in section 3217(a)(1) of the Public Resources Code,
10 Respondents aze prohibited from authorizing SoCa1Gas to inject any natural gas into the Aliso
1 1 Canyon facility until(1)"a comprehensive review ofthe safety of the gas storage wells at the
12 facility is completed and the supervisor determines that well integrity has been ensured by the
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13 review";(2)"the risks of failures identified in the review have been addressed"; and (3)"the
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14 supervisor's duty to prevent damage to life, health, property, and nahual resources, and other

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IS requirements, as specified in Section 3106, is satisfied."
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17 root-cause analysis is complete. Respondents cannot identify, let alone address, the risks offailure

m posed by the Aliso Canyon facility until the cause ofthe leak is known.
[
C~ 122. In addition, Respondents have not addressed the seismic risks identified during
20I their review. Instead, Respondents have identified seismic risks, but have not taken action, or

21 created mitigation protocols, to address those risks.

22 123. Nor have Respondents addressed the risk management plan and emergency
23 response program necessary for the protection and preservation of health and life as required by

24 SB 380 and section 3106 of the Public Resources Code.

25 124. A writ of mandate is necessary to compel Respondents to address the risks of


26 failure identified in the root-cause analysis and to address seismic risks before approving injection

27 of natural gas into the Aliso Canyon facility.


28

333539.13
23
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
125. SB 380, codified in section 3217(d)ofthe Public Resources Code, requires a duly

noticed public hearing to be held upon Respondents' completion of the gas storage well

comprehensive safety review but before authorizing the commencement of injections at the Aliso

Canyon facility.

126. SB 380, codified in Section 3217(c)(5) of the Public Resources Code, states the gas

storage well comprehensive safety review is not complete until every gas storage well at the Aliso

Canyon facility has completed testing.

127. Respondents held the public hearing before they completed testing on all gas

storage wells and before the saFety review was completed.

10 128. The County possesses a beneficial interest in the outcome of this proceeding in

1 1 ensuring the health and safety of its residents and in ensuring that its resources are used to respond

12 to another disastrous leak.


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IS 130. The County has notified Respondents that they have failed to comply with their
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16 duties under SB 380, but Respondents have failed or refused to take necessary action.
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17 131. Due to the continuing risk of harm to the public and DOGGR's failure to comply
O

18 with its legal obligations before authorizing injection of natural gas at Aliso Canyon, the County
'
a

19 has no adequate remedy at law, entitling it to injunctive relief. As first responders to public health

20 and environmental disasters, the County cannot wait until another disaster occurs. Without access

21 to the safety review documents and root-cause analysis documents thaC the County requested in iCs

22 PRA,the County cannot review DOGGR's actions.

23 132. Injunctive relief is necessary to preserve and protect the public interest. By this
24 action, the County seeks to maintain the status quoi.e., no injection of gas at high pressure into

25 Aliso Canyonuntil DOGGR satisfies its legal obligations under SB 380. Neither DOGGR nor

26 ~oCalGas will suffer grave or irreparable harm from a writ of mandate or injunction requiring

27 Zespondents to comply with SB 380 before approving injection of gas at Aliso Canyon.

28

'33539.13
24
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
133. For all the reasons set forth above, this Court should find that Respondents are
2 II prohibited from approving injection of natural gas into the Aliso Canyon facility until

Respondents comply with their obligations under SB 380.

SECOND CAUSE OF ACTION

(Declaratory Relief Code of Civil Procedure 1060)

134. Petitioner incorporates by reference the foregoing paragraphs of this Petition as if


set forth fully herein and further contends as follows.

A. SB 380

135. A dispute and actual controversy has arisen and now exists between the County and

10 Respondents concerning their respective rights and duties under SB 380, including but not limited

1 1 I to:

12. a. whether Respondents must address the risks identified in the root-cause
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14 before authorizing injection of natural gas at the Aliso Canyon facility;
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15 b. whether Respondents must address a final risk management plan and
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~6 16 effective emergency response plan from SoCalGas as part ofthe
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17 comprehensive safety review mandated by SB 380 before authorizing
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18 injection of natural gas at the Aliso Canyon facility;

19 c. whether Respondents must address the seismic risks to the facility as part of
20 the comprehensive safety review mandated by SB 380 before authorizing
21 injection of natural gas at the Aliso Canyon facility;
22 d. whether Respondents have complied with their mandatory duties under SB
23 380 to address the risks offailure identified in the safety review;
24 e. whether the comprehensive safety review was complete as of January 17,
25 2017;
26 whether all 114 gas storage wells at Aliso Canyon had satisfactorily met
27 one of the following categories as of January 17, 2017, and, alternatively,
28 February 6, 2017: (1) completed the testing and remediation required by

333539.13
25
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
1 SB 380;(2) been temporarily abandoned and isolated from the reservoir or

2 (3)been fully plugged and abandoned to the supervisor's satisfaction;

3 g. whether, as of February 1, 2017, Aliso Canyon well Porter 32 was still

4 undergoing SB 380 testing and had therefore not satisfactorily met one of

5 the following categories: (1) completed the testing and remediation

6 required by SB 380(2)been temporarily abandoned and isolated from the

7 reservoir or(3) been fully plugged and abandoned to the supervisor's

8 satisfaction;

9 h. whether Respondents complied with their mandatory duty to post safety

10 review-related materials on the public portion of DOGGR's website; and

11 i. whether Respondents complied with their mandatory duty under SB 380 to


0
12 hold a public meeting to allow the public to comment on the results of the
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17 137. Section 21151 of the Public Resources Code directs all local agencies to "prepare,

18 or cause to be prepared by contract, and certify the completion of, an environmental impact report

19 on any project that they intend to carry out or approve which may have a significant effect on the

20 environment."

21 138. The EIR required by section 21151 "is the heart of CEQA."

22 139. As the lead agency, DOGGR has an obligation to produce an EIR before approving

23 reinjection of nahual gas into the Aliso Canyon facility.

24 140. The County requested that DOGGR comply with CEQA before authorizing

25 injection at Aliso Canyon. DOGGR has refused and has not produced an EIR for the Aliso

26 Canyon facility before approving reinjection of natural gas. This is improper under, and in

27 violation of, CEQA.

28 141. CEQA exempts certain classes of projects, Cal. Pub. Res. Code 210&0(b)(9),

333539.13 2f
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATOR
20184(a), but none of the "categorical exemptions" apply. The project does not fall within any of

the "categorical exemptions" because the project will result in a substantial increase in the existing
use of the Aliso Canyon facility.
142. SoCa1Gas has not injected gas into the Aliso Canyon facility since at least October
2015; and thus natural gas injections will expand the use ofthe Aliso Canyon faciliTy and will

have a significant impact on the existing environment.


143. Even if a categorical exemption did apply,"unusual circumstances" prohibit the use
ofthat exemption because the nature, size and location of Aliso Canyon, among other things,

0 create a reasonable possibility ofa substantial effect on the envirorunent.


10 144. Petitioner informed Respondents of their CEQA obligations with respect to the

I1 Aliso Canyon facility through written submissions and oral statements at the recent public hearing
0
12 on the project.
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14 I to prepare an EIR.

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~ ~~~ ~J 146. Declazatory relief is necessary to inform Respondents of their obligations under

~ <~ 16 CEQA and to order them to comply with State law.


w .n
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~ Y
~ / PRAYER FOR RELIEF
O p

w 10 WHEREFORE,Petitioner prays for the following relief:


19 For a writ of mandate directing Respondents to comply with their obligations under

m SB 380 before authorizing natural gas injection into the Aliso Canyon facility;
21 2. For injunctive relief and an immediate stay of any authorization to inject natural

22 gas into the Aliso Canyon facility;

23 3. For a declaration that Respondents have violated the requirements of SB 380 as


24 alleged herein;

25 4. For declazatory relief requiring Respondents to comply with SB 380 and CEQA

26 before authorizing injection at Aliso Canyon;

27 5. For costs of suit and attorneys' fees; and

28

333539.13 2'~
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF
1 6. For other and further relief as the Court finds proper.

2
3 DATED: March 8,2017 MILLER BARONDE3S,LLP

4
5 By: ~~
6 LOUIS R. MILLER
SCOTT KUHN,OFFICE OF THE COUNTY
7 COUNSEL
8 Attorneys for Petitioner
9 THE COUNTY OF LOS ANGELES

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333539.13 Z8
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF

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