1 6 R. Rex Parris Esq. (SBN 96567) rrexparris@rrexparris.com Patricia K. Oliver, Esq. (SBN 193423) poliver@rrexparris.com Ethan Litney, Esq. (SBN 295603) elitney@rrexparris.com R. REX PARRIS LAW FIRM 43364 10th Street West Lancaster, California 93534 Telephone: (661) 949-2595 Facsimile: (661) 949-7524 7 Attorneys for Plaintiffs and the Putative Class 2 3 4 5 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES 10 11 12 13 ROBYN SHAPIRO, an individual, individually, MATTHEW PAKUCKO, an individual, SUSAN I. GORMAN-CHANG, an individual, NATHAN HEMMINGER, an individual, GABRIEL KHANLIAN, an individual, SAVE PORTER RANCH, a California non-profit Corporation, and on behalf of all others similarly situated, 14 Plaintiffs, 15 v. 16 SOUTHERN CALIFORNIA GAS COMPANY, a California Corporation, SEMPRA ENERGY a California Corporation, STATE OF CALIFORNIA, DIVISION OF OIL, GAS and GEOTHERMAL RESOURCES, a state agency, DOES 1 through 100, inclusive; 17 18 19 CLASS ACTION COMPLAINT 1. 2. 3. 4. 5. NEGLIGENCE TRESPASS PRIVATE NUISANCE PUBLIC NUISANCE INVERSE CONDEMNATION DEMAND FOR JURY TRIAL Defendants. 20 21 Case No. Plaintiffs Robyn Shapiro, Save Porter Ranch, Matthew Pakucko, Susan I. Gorman-Chang, 22 Nathan Hemminger, Gabriel Khanlian, and (“Plaintiffs”) through undersigned counsel hereby 23 bring this class action (“Complaint”) against Defendants Sempra Energy (“Sempra”), Southern 24 California Gas Company (“So. Cal. Gas”), and DOES 1-100. Plaintiffs aver the following upon 25 personal knowledge and information and belief based upon the investigation of counsel as to all 26 other facts alleged in the Complaint. INTRODUCTION 27 28 1. This case involves the massive leak that was discovered on or about October 23, ________________________________________________________________________________ COMPLAINT Page 1 1 2015 next to the residential community of Porter Ranch. This gas is not from the region, but 2 instead the gas is injected underground by Defendant Southern California Gas Co. (So. Cal. Gas) 3 into illegally permitted wells. In September of 2015, So. Cal. Gas injected 5.7 billion cubic feet 4 of gas underground near the residents of Porter Ranch. So. Cal. Gas was injecting what is 5 believed to be similar amounts of gas in October when one of the injection wells suffered a 6 massive well failure and blowout, leading to the leak. The gas from this So. Cal. Gas injection 7 has now leaked into the air and into the water table. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2. The 30,000 residents of Porter Ranch began experiencing toxic impacts from the air 25 contamination shortly after the massive failure of the gas injection well. These residents have 26 now been exposed to an uninterrupted flow of gases, including methane, mercaptans, and 27 aromatic hydrocarbons. The residents of Porter Ranch suffer physical problems including 28 neurological, gastrointestinal, and respiratory ailments, including dizziness, light-headedness, ________________________________________________________________________________ COMPLAINT Page 2 1 nausea, vomiting, headaches, and nosebleeds. The residents also are being forced to move to 2 avoid the impact of this physical trauma. So. Cal. Gas informed the community that this will 3 likely continue for the next three to four months. 4 3. No one has yet quantified the impact of this gas leak on the community with respect 5 to the transfer of this gas through the underground water. So. Cal. Gas has likewise not explained 6 who is assisting to prevent contamination to the water impacted by this massive well failure for 7 the agencies and individuals who may use this water. 8 4. So. Cal. Gas’s Aliso Canyon natural gas storage reservoir is located approximately 9 one mile from the Porter Ranch community, and it is one of the nation’s largest natural gas 10 storage reservoirs. The injection well allegedly at fault for the gas leak (API No. 03700776) is an 11 8,750-foot-deep gas and located in this reservoir. So. Cal. Gas injected gas directly into this well 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ________________________________________________________________________________ COMPLAINT Page 3 1 when the massive well failure occurred. The public records reveal that So. Cal. Gas did not follow 2 the laws protecting the community when it decided to inject into this well and into other nearby 3 injection wells. 4 5. So. Cal. Gas’s attempt to overcome the immense pressure exerted by the escaping 5 gas failed. All subsequent attempts by So. Cal. Gas also failed. As a result, gas is escaping from 6 the Aliso Canyon Oil Field at an astounding rate of 50,000 kilograms per hour. Upwards of 25% 7 of all methane released in California is now being released from this one injection well. The 8 difficulties faced by So. Cal. Gas in controlling the high-pressure leak in one injection well are 9 surely exacerbated by any continued high-pressure injection of billions of cubic feet of natural gas 10 into the same shared gas-storage reservoir. Of greater concern, the continued injections create a 11 serious public health risk for the families in Porter Ranch. The toxic release of gas is so severe, 12 experts brought to stop the fires in Kuwait in 1991 are now handling this massive gas leak. 13 6. On November 18, 2015, Steve Bohlen, State Oil & Gas Supervisor at the Division of 14 Oil, Gas, and Geothermal Resources (“DOGGR”) issued an emergency order requiring So. Cal. 15 Gas to provide all testing data and remediation plans. 16 7. DOGGR did not issue any order to stop continued injections by So. Cal. Gas. 17 Plaintiffs sent a letter demanding that all injections cease at least until the gas leak itself is fixed. 18 Attached hereto and incorporated herein by this reference as Exhibit 1 is a copy of this letter. 19 8. Indeed, continued injections may increase the release of natural gas by forcing the 20 gas into the water, open crevices, and airways. For example, when an injection well pushes gas 21 underground, the gas may migrate into the water and into idle wells. Thus far, it appears that the 22 leak in this instance by So. Cal. Gas migrated into the water, and the ultimate destination of this 23 gas is unclear. It is critical that both So. Cal. Gas and DOGGR address where the gas is migrating 24 because the presence of gas in water creates serious health and safety problems. 25 9. The families of Porter Ranch suffered and continue to suffer both physical and 26 financial injuries including exposure to dangerous levels of noxious odors, hazardous gases, 27 chemicals, pollutants, and contaminants released into the air and water by So. Cal. Gas. 28 10. The severity of the gas leak led Los Angeles County health officials to order ________________________________________________________________________________ COMPLAINT Page 4 1 Defendants to offer temporary lodging accommodations to affected residents due to the buildup of 2 dangerous levels of toxic chemicals. At this time, reports suggest that over 300 families sought 3 relocation from Porter Ranch. 4 11. As a result, in the midst of the holiday season, families in Porter Ranch face the 5 choice of waking each morning breathing grossly polluted air, or being forced to relocate and 6 miss school. Either way, the massive leak from improperly permitted activities increases family 7 stress beyond and above what anyone otherwise faces during the holidays. And So. Cal. Gas 8 admits its current plan to stop the leak will take at least three to four months. Worse yet, there is 9 no guarantee of success and no end of the stress in sight for these families. 10 11 FACTUAL ALLEGATIONS 12. 12 So. Cal. Gas is the nation’s largest natural gas distribution utility. Natural gas is a 13 hydrocarbon gas mixture consisting primarily of methane. Methane is a greenhouse gas that is 14 eighty-four times more potent than carbon dioxide. In addition, natural gas includes varying 15 amounts of other toxic chemicals including carbon dioxide, nitrogen and hydrogen sulfide. 13. 16 So. Cal. Gas pipes in natural gas and then injects the natural gas underground in 17 Aliso Canyon for later distribution. This oilfield includes over one hundred injection wells, most 18 of the wells are injection wells for storage of natural gas. This particular facility is the largest of 19 the four gas storage fields owned and operated by So. Cal. Gas in Southern California. So. Cal. 20 Gas converted what was an older oil field into primarily a gas storage facility years ago. So. Cal. 21 Gas now operates over 150 injection wells in the Aliso Canyon Oil Field, including over 90 active 22 gas storage injection wells injecting into the Sesnon-Frew reservoir. 14. 23 So. Cal. Gas also relies upon injection wells to dispose of toxic waste water from oil 24 and gas operations and to inject water to force oil and gas from one part of the formation to 25 another part of the formation. The map on the next page depicts some of the wells at issue. It 26 does not include the idle wells that can serve as pathways for gas to leak out of the formation. 27 //// 28 //// ________________________________________________________________________________ COMPLAINT Page 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 15. Natural gas is odorless. Thus So. Cal. Gas adds a chemical compound generally 18 called mercaptans prior to distribution to consumers. The addition of this compound allows 19 detection of leaks because of the foul, rotten egg smell from these mercaptans, making the odor 20 unbearable for people to smell. 21 16. On October 23, 2015 So. Cal. Gas reported that it detected an uncontrolled flow of 22 fluids and gas from gas injection well “Standard Sesnon 25” (API no. 03700776), completed in 23 the Sesnon-Frew reservoir in the Aliso Canyon Oil Field. In the month prior to the leak, over 45 24 wells injected over 5.7 billion cubic feet of gas into the Sesnon-Frew reservoir. 25 17. The California Air Resources Board released a report estimating that natural gas at 26 the Aliso Canyon storage facility is currently leaking at a rate of approximately 50,000 kilograms 27 per hour. Other estimates suggest that this is 25% of all methane released in California. 28 18. So. Cal. Gas made numerous attempts to abate the leaking of fluids and gas --- all ________________________________________________________________________________ COMPLAINT Page 6 1 have failed because the pressure of gravity pushing the gas outside of the formation is too great to 2 stop the migration of this gas. So. Cal. Gas first filled the well bore with heavy brine and barite 3 solutions – this created more damage as it exploded upwards into the air. So. Cal. Gas now seeks 4 to drill a new well to overcome the reservoir pressure, but it cannot confirm this will be sufficient. 5 Because of the size of the storage facility, So. Cal. Gas does not appear to have any plans to 6 actually remove natural gas stored at this location. 7 19. Mercaptans were present in the gas leaking from the injection well operated by So. 8 Cal. Gas in Aliso Canyon. Mercaptans are usually added just prior to distribution to consumers 9 and not during the storage process. 10 20. Even at low levels of exposure, mercaptans can cause eye, nose and throat irritation, 11 coughing and nasal congestion, shortness of breath, nausea, stomach discomfort, vomiting, 12 dizziness, and headaches. These adverse health effects will continue so long as persons are 13 exposed to the mercaptans. 14 21. The Division of Oil, Gas, and Geothermal Resources (“DOGGR”) is one of the 15 California agencies responsible for regulation and enforcement of the gas and oil operations, and 16 in particular, DOGGR is responsible for enforcement of regulations of all underground injection 17 wells. This is part of the underground injection control (“UIC”) program. 18 22. On November 18, 2015, DOGGR State Oil and Gas Supervisor Steve Bohlen issued 19 an emergency order requiring So. Cal. Gas to submit its testing dating related to the uncontrolled 20 fluid and gas leak within 24 hours and its planned remediation schedule within 48 hours. 21 Specifically, the emergency order demanded that So. Cal. Gas provide continuous access to real- 22 time electronic monitoring of wellhead pressures, diagnostic tests, downhole videos and well logs, 23 pressure and other surveys. In addition, it demanded So. Cal. Gas provide a timeline for when it 24 will prepare a relief well site, and when such drilling will begin. 25 23. The uncontrolled gas leak is harming the residents of Porter Ranch. This natural gas 26 includes methane, mercaptans, benzene, toluene, hydrogen sulfides, and sulfur dioxide. These 27 chemicals are impairing the health of residents of Porter Ranch including the named plaintiffs and 28 impairing their ability to remain in their residences. Residents suffer from an inability to breathe ________________________________________________________________________________ COMPLAINT Page 7 1 comfortably due to the pungent odors and suffer from dizziness, light-headedness, nausea, 2 headaches, vomiting, and nosebleeds. 3 24. On November 19, 2015, the Los Angeles County Department of Public Health 4 directed So. Cal. Gas to expedite leak abatement and to provide free, temporary relocation to any 5 residents affected by the gas leak. At this time, approximately 300 families have requested 6 relocation. 7 25. In sum, So. Cal. Gas and its parent company, Defendant Sempra Energy 8 (“Defendants”), negligently failed to construct, operate, and maintain the Aliso Canyon natural 9 gas storage facility where they inject gas and other products into improperly permitted injection 10 wells in the Aliso Canyon field. 11 26. Defendants’ failure to abate the fluid and gas leak is releasing hazardous gases, 12 chemicals, pollutants, and contaminants into Plaintiffs’ land, homes, and/or their persons. These 13 leaks, releases, emissions, and/or migration of noxious odors, hazardous gases, chemicals, 14 pollutants, and contaminants into Plaintiffs’ land, homes, and/or their persons constitute an 15 invasion of Plaintiffs’ property. 16 27. The leaks, releases, emissions, and/or migration of noxious odors, hazardous gases, 17 chemicals, pollutants, and contaminants into Plaintiffs’ land, homes, and/or their persons has 18 substantially impaired Plaintiffs’ use and enjoyment of both their property and all of the public 19 property located around the Porter Ranch community. 20 21 JURISDICTION AND VENUE 28. Each Defendant transacts a substantial amount of business and/or have agents within 22 Los Angeles County. The unlawful acts alleged herein took place in Los Angeles County. The 23 unlawful acts alleged herein have a direct effect on Plaintiffs and those similarly situated within 24 Los Angeles County. Further, the amount in controversy exceeds the jurisdictional minimum, 25 exclusive of interests and costs. 26 29. Venue is proper in this Court pursuant to California Civil Procedure sections 395 27 and 395.5 since Defendant So. Cal. Gas is headquartered in Los Angeles County and is regularly 28 engaged in transactions in Los Angeles County. ________________________________________________________________________________ COMPLAINT Page 8 1 2 PARTIES 30. Plaintiff Robyn Shapiro is an individual, who currently and at all times relevant to 3 this action, resides in resident of Los Angeles County, California. Her residence is located in the 4 Porter Ranch community of Los Angeles, California, nearby the uncontrolled gas well leak at 5 Defendants’ Aliso Canyon storage facility. 6 7 8 9 10 11 12 13 14 15 16 17 31. Plaintiff Matthew Pakucko is an individual, who currently and at all times relevant to this action, resides in Los Angeles County, California. His residence is located in the Porter Ranch community of Los Angeles, California, nearby the uncontrolled gas well leak at Defendants’ Aliso Canyon storage facility. 32. Plaintiff Susan I. Gorman-Chang is an individual, who currently and at all times relevant to this action, resides in Los Angeles County, California. Her residence is located in the Porter Ranch community of Los Angeles, California, nearby the uncontrolled gas well leak at Defendants’ Aliso Canyon storage facility. 33. Plaintiff Nathan Hemminger is an individual, who currently and at all times relevant to this action, resides in resident of Los Angeles County, California. His residence is located in the Porter Ranch community of Los Angeles, California, nearby the uncontrolled gas well leak at Defendants’ Aliso Canyon storage facility. 34. Plaintiff Gabriel Khanlian is an individual, who currently and at all times relevant to 18 this action, resides in resident of Los Angeles County, California. His residence is located in the 19 Porter Ranch community of Los Angeles, California, nearby the uncontrolled gas well leak at 20 Defendants’ Aliso Canyon storage facility. 21 35. Defendant So. Cal. Gas is a California corporation with its principal place of 22 business in Los Angeles, California. So. Cal. Gas is the nation’s largest natural gas distribution 23 utility, servicing 21.4 million consumers through 5.9 million meters in more than 500 24 communities. 25 26 27 28 36. Defendant Sempra Energy is a California corporation with its principal place of business in San Diego, California. Sempra Energy is the parent company of So. Cal. Gas. 37. Defendant the State of California, Division of Oil, Gas, and Geothermal Resources (“DOGGR”) is a California state governmental entity, domiciled in California, which has been ________________________________________________________________________________ COMPLAINT Page 9 1 delegated certain permitting responsibilities under state and federal environmental laws. Among 2 other items, DOGGR must “address the needs of the state, local governments, and industry by 3 regulating statewide oil and gas activities with uniform laws and regulations.” DOGGR also 4 “supervises the drilling, operation, maintenance, and plugging and abandonment of onshore and 5 offshore oil, gas, and geothermal wells, preventing damage to: (1) life, health, property, and 6 natural resources; (2) underground and surface waters suitable for irrigation or domestic use; and 7 (3) oil, gas, and geothermal reservoirs.” DOGGR’s activities described in this action involve 8 employees in several districts including District 1 (Los Angeles County and Orange County. 9 District 1 offices are located at 5816 Corporate Avenue, Suite 100, Cypress, California, 90630. 10 38. Does 1 through 100, inclusive are the partners, agents, employees or principals, and 11 the co-conspirators of the named Defendants, and of each other whose true names and capacities 12 are currently unknown to Plaintiffs; the named defendants and Does 1 through 100, inclusive, 13 performed the acts and conduct herein alleged, aided and abetted the performance thereof, or 14 knowingly acquiesced in, ratified, and accepted the benefits of such acts and conduct; and 15 therefore, Does 1 through 100, inclusive, are liable to Plaintiffs to the extent of the liability of the 16 named Defendants. Plaintiffs will seek leave of the Court to amend its Complaint to reflect the 17 true names and capacities of the Defendants designated herein as DOES when such identities and 18 capacities become known. 19 39. Based on information and belief, Plaintiffs allege that at all times mentioned herein, 20 each and every Defendant was acting as an agent and/or employee of each of the other 21 Defendants, and at all relevant times mentioned was acting within the course and scope of said 22 agency and/or employment with the full knowledge, permission, and consent of each of the other 23 Defendants. In addition, each of the acts and/or omissions of each Defendant alleged herein were 24 made known to, and ratified by, each of the other Defendants. 25 26 CLASS ACTION ALLEGATIONS 40. Plaintiffs bring this case as a class action on behalf of themselves and all other 27 similarly situated individual as a class action pursuant to California Code of Civil Procedure 28 section 382. ________________________________________________________________________________ COMPLAINT Page 10 1 41. Plaintiffs seek to represent all California residents who have been exposed to the 2 noxious odors, hazardous gases, chemicals, pollutants, and contaminants emanating from the 3 natural gas leak at Defendants’ Aliso Canyon Storage Facility, since the leak was discovered. 4 The proposed class (“Class”) is comprised entirely of California residents who live in the Porter 5 Ranch community of Los Angeles, California. 6 42. This action is perfectly suited for class action treatment since a well-defined 7 community of interest in the litigation exists and the class is easily ascertainable. The 8 aforementioned class definition identifies a group of unnamed plaintiffs by a set of shared 9 characteristics adequate for an individual to identify him or herself as a member of the group with 10 the right to recover. The class members may receive proper and sufficient notice either directly or 11 through publication. 12 43. Commonality and Predominance: Defendants’ conduct and the scope of its impact 13 raise common issues of fact and law among all members of the class, and common questions of 14 law or fact are substantially similar and predominate over questions that may affect only 15 individual class members. Defendants’ unreasonable construction, operation, or maintenance of 16 the Aliso Canyon natural gas storage facility is a common nucleus of operative fact linking every 17 class member. Each member of the proposed class claims that Defendants negligently 18 constructed, operated, and/or maintained their Aliso Canyon natural gas storage facility, which 19 resulted in harmful pollutants and noxious odors to invade their land, causing diminished use and 20 enjoyment of their properties, polluted land and air in and around Plaintiffs’ properties, and 21 adverse health effects. In addition, each member of the proposed class also claims that the 22 Defendants have intentionally, recklessly, and/or negligently failed to abate the leak of harmful 23 pollutants and noxious odors. And while slight variations in the individual damage claims may 24 occur, common questions of law or fact regarding Defendants’ liability substantially predominate 25 over any questions affecting only individual class members such that the class members should be 26 permitted for the fair and efficient adjudication of this controversy. 27 28 44. Plaintiffs assert that they intend to prove Defendant was responsible for class-wide harm with admissions from Defendants, expert testimony, scientific evidence of the pollutants’ ________________________________________________________________________________ COMPLAINT Page 11 1 dispersion, and illustrative testimony from the Plaintiffs themselves and the neighbor-declarants 2 who reside throughout the class area. Almost identical evidence will be required to establish the 3 level and duration of Defendants’ emissions, the reasonableness of Defendants’ operations, and 4 the causal connection between the injuries allegedly suffered and Defendants’ liability. This 5 evidence is common to all class members and will require substantial trial time. 6 7 8 45. Common questions of law and fact common to Plaintiffs and the class members include, but are not limited to, the following: a. Whether Defendants properly received permits from DOGGR to inject gas into 9 this field, and whether the permits complied with the UIC regulations protecting 10 the community from the toxins; 11 12 13 14 15 16 b. Whether Defendants acted reasonably in the construction, operation, or maintenance of the injection wells in Aliso Canyon; c. Whether Defendants were negligent in the construction, operation, or maintenance of the injection wells in Aliso Canyon; d. Whether Defendants were negligent in their attempts to abate the fluid and gas leak from their injection wells in Aliso Canyon; 17 e. Whether Defendants owed a duty to the class members; 18 f. Whether Defendants’ duty to the class members was breached; 19 g. Whether Defendants’ breach of duty to class members was the actual and 20 proximate cause of the uncontrolled natural gas leak that occurred on October 21 23, 2015, and continues to occur as of the filing of this Complaint; 22 h. Whether gases and other chemicals have been leaked, released or emitted into 23 the area of the natural gas leak at Defendants’ Aliso Canyon natural gas storage 24 facility that would pose a threat to the health and safety of the class members; 25 i. Whether it was reasonably foreseeable that Defendants’ failure to properly 26 construct, operate or maintain the Aliso Canyon natural gas storage facility and 27 its injection wells would result in harm to the class members; 28 j. Whether it was reasonably foreseeable that Defendants’ failure to properly ________________________________________________________________________________ COMPLAINT Page 12 1 construct, operate or maintain the Aliso Canyon natural gas storage facility and 2 its injection wells would result in an invasion of the class members’ use and 3 enjoyment of their property; 4 k. Whether uncontrolled leak of noxious odors, hazardous gases, chemicals, 5 pollutants, and contaminants into the area at Defendants’ Aliso Canyon natural 6 gas storage facility constitutes an unlawful trespass; 7 l. The magnitude to which the class members have been harmed by the 8 uncontrolled leak of noxious odors, hazardous gases, chemicals, pollutants, and 9 contaminants into the area at Defendants’ Aliso Canyon natural gas storage 10 facility; and 11 12 m. The appropriate measure of damages sustained by the class members. 46. Numerosity: The members of the Class are so numerous that a joinder of all 13 members would be impracticable. Plaintiffs estimate, according to a report released by the Los 14 Angeles Department of City Planning, that the population of Porter Ranch was estimated to be 15 approximately 30,571 in 2008. While the exact number of members of the Class is presently 16 unknown to Plaintiffs and can only be determined through discovery, Plaintiff believes the Class 17 is likely to include thousands of members. 18 47. Typicality: Plaintiffs’ claims are typical of the claims of the class. Plaintiffs and all 19 putative class members are subject to the same uncontrolled gas well leak at Defendants’ Aliso 20 Canyon storage facility. Defendants’ course of conduct in violation of law as alleged herein has 21 caused Plaintiffs and class members to sustain the same or similar injuries and damages. 22 48. Adequacy of Representation: Plaintiffs and all putative class members do not have 23 any conflicts of interest with other class members due to the great degree of commonality, and 24 will prosecute the case vigorously on behalf of the class. Counsel representing Plaintiffs and the 25 class are competent and experienced in litigating large environmental class actions. Plaintiffs will 26 fairly and adequately represent and protect the interests of the class members. Thus, the named 27 Plaintiffs are committed to deliver relief for the class and have retained experienced class action 28 counsel. ________________________________________________________________________________ COMPLAINT Page 13 1 49. Superiority of class action: A class action is superior to other available means for 2 the fair and efficient adjudication of this controversy. Individual joinder of all class members is 3 not practicable, and questions of law and fact common to the class predominate over any 4 questions affecting only individual members of the class. Each class member has been damaged 5 and is entitled to recovery as a direct result of Defendants’ conduct with respect to the 6 uncontrolled gas well leak at Defendants’ Aliso Canyon storage facility. Moreover, the 7 complexity of this litigation and potential of recovery for individuals renders separate 8 adjudication impracticable. Thus, class action treatment provides optimal resolution of all the 9 class members claims in a manner most efficient and economical for both the parties and the 10 judicial system. 11 CLAIMS FOR RELIEF 12 FIRST CLAIM FOR RELIEF 13 NEGLIGENCE / NEGLIGENCE PER SE (CALFORNIA LAW) 14 C ALIFORNIA E VIDENCE C ODE § 669 15 (Against Defendants So. Cal. Gas and Sempra)1 16 17 18 19 20 50. Plaintiffs re-allege and incorporate the foregoing paragraphs as though fully set forth 51. Plaintiffs are individuals who each own or rent residential property within a short herein. distance of the Aliso Canyon gas storage facility owned and/or operated by Defendants. 52. Defendants own, operate, or service a gas storage facility and numerous injection 21 wells near Plaintiffs’ residences. Defendants thus have a duty to use reasonable care in the 22 construction, operation, maintenance and abandonment of all such operations and equipment. 23 24 53. Defendants breached that duty by negligently and carelessly constructing, operating, and/or maintaining the Aliso Canyon storage facility and injection wells. This negligence directly 25 26 27 28 1 Plaintiffs will file separate tort claims against the State of California for all personal injury damages sustained as a result of the failure of the state to properly permit the wells in question. Such claims will be joined upon expiration of the time period to compensate Plaintiffs. Plaintiffs’ claims for inverse condemnation are not subject to the tort claim requirement. ________________________________________________________________________________ COMPLAINT Page 14 1 and foreseeably caused actual leaks, releases, emissions, and/or migration of noxious odors, 2 hazardous gases, chemicals, pollutants, and contaminants into Plaintiffs’ land and homes. 3 54. Defendants knew or should have known that their operations would result in the 4 leaks, releases, emissions, and/or migration of pollutants including but not limited to noxious 5 odors, hazardous gases, chemicals, pollutants, and contaminants, and that such pollutants would 6 contaminate Plaintiffs’ land, homes, and/or persons. 7 55. The breach of duty by Defendants directly increased the concentration of noxious 8 odors, hazardous gases, chemicals, pollutants, and contaminants on Plaintiffs’ land and person to 9 such an extent that Plaintiff has suffered both personal and property damage. In addition, Los 10 Angeles County health officials have ordered Defendant to offer free temporary housing 11 accommodations to many of the families who are members of Plaintiff due to the buildup of 12 dangerous levels of noxious odors, hazardous gases, chemicals, pollutants, and contaminants 13 because continued exposure poses a serious health risk. 14 56. The breach of duty by Defendants was the legal and proximate cause of the injuries 15 and damages suffered by Plaintiffs. The damages caused by the breach included polluted land and 16 air in and around Plaintiffs’ properties and adverse health effects suffered by Plaintiffs due to 17 exposure. 18 57. Additionally, Defendants had an obligation not to violate the law with respect to 19 construction, operation, and maintenance of its Aliso Canyon storage facility and its injection 20 wells. 21 58. Due to Defendants’ activities, actions, and/or inactions, Plaintiffs experienced 22 serious health effects including, but not limited to: dizziness, nausea, drowsiness, headaches, and 23 nose bleeding. 24 59. Defendants have shown a willful disregard for public health and health and safety of 25 Plaintiffs, to others similarly situated, and the community through its failure to abate the harm 26 after more than a month. 27 28 60. Defendants failed to meet the standard of care set by the above statutes and regulations, which were intended for the benefit of individuals such as Plaintiffs, making ________________________________________________________________________________ COMPLAINT Page 15 1 Defendants’ conduct negligent per se. As a result of violation of the above statutes, Plaintiffs 2 suffered injuries and damages as alleged herein. 3 4 61. Plaintiffs are within the class of persons the above statutes and regulations are designed to protect, and their injuries are the type of harm these statutes are designed to prevent. 5 62. Defendants actions resulted in the pollution of air and deprived residents of Porter 6 Ranch of their ability to live in their homes free of health problems. Defendants took these 7 actions with a willful and knowing disregard of the rights and safety of the community. Plaintiffs 8 should, therefore, be awarded punitive and exemplary damages under Civil Code section 3294 9 sufficient to punish Defendants for engaging in this conduct and to deter similar conduct in the 10 future. 63. 11 12 13 14 15 16 17 18 As a further result of this wrongful conduct, Plaintiffs suffered, and will continue to suffer, the loss of the quiet use and enjoyment of its property in addition to all of their general damages in an amount to be set forth according to proof at trial. 64. In addition, Plaintiffs should be awarded attorney’s fees under Code of Civil Procedure section 1021.5 because the successful prosecution of this action will confer a significant benefit both pecuniary and non-pecuniary on the general public and a large class of persons by abating environmental harm and preventing future harm to residents of Porter Ranch. Further, the necessity and financial burden of private enforcement makes such an award appropriate as the litigation is not economically feasible or viable for Plaintiffs to pursue on their 19 own at their own expense, and such fees should not in the interest of justice be paid out of the 20 recovery, if any. 21 SECOND CLAIM FOR RELIEF 22 TRESPASS (CALIFORNIA LAW) 23 C ALIFORNIA C IVIL C ODE § 3334 24 (Against Defendants So. Cal. Gas and Sempra) 25 26 27 28 65. Plaintiffs re-allege and incorporate the foregoing paragraphs as though fully set forth 66. In the construction, operation, and/or maintenance of the Aliso Canyon storage herein. facility and injection wells owned and/or operated by Defendants, Defendants intentionally, ________________________________________________________________________________ COMPLAINT Page 16 1 recklessly, willfully, and/or negligently caused dangerous levels of noxious odors, hazardous 2 gases, chemicals, pollutants, and contaminants to enter onto Plaintiffs’ properties by leaks, 3 releases, emissions, and/or migration from the Aliso Canyon storage facility. 4 67. Plaintiffs did not give permission for this entry. 5 68. Plaintiffs suffered harm from Defendants’ conduct including, but not limited to, 6 polluted land and air in and around Plaintiffs’ property and adverse health effects due to exposure. 7 8 69. Defendants’ actions were a substantial factor in causing the harm to the Plaintiffs as there were no other independent causes of the trespass onto Plaintiffs’ properties. 9 70. Defendants actions resulted in the pollution of air and deprived residents of Porter 10 Ranch of their ability to live in their homes free of health problems. Defendants took these 11 actions with a willful and knowing disregard of the rights and safety of the community. Plaintiffs 12 should, therefore, be awarded punitive and exemplary damages under Civil Code section 3294 13 sufficient to punish Defendants for engaging in this conduct and to deter similar conduct in the 14 future. 71. 15 16 17 18 19 20 21 22 As a further result of this wrongful conduct, Plaintiffs suffered, and will continue to suffer, the loss of the quiet use and enjoyment of its property in addition to all of their general damages in an amount to be set forth according to proof at trial. 72. In addition, Plaintiffs should be awarded attorney’s fees under Code of Civil Procedure section 1021.5 because the successful prosecution of this action will confer a significant benefit both pecuniary and non-pecuniary on the general public and a large class of persons by abating environmental harm and preventing future harm to residents of Porter Ranch. Further, the necessity and financial burden of private enforcement makes such an award appropriate as the litigation is not economically feasible or viable for Plaintiffs to pursue on their 23 own at their own expense, and such fees should not in the interest of justice be paid out of the 24 recovery, if any. 25 //// 26 //// 27 //// 28 //// ________________________________________________________________________________ COMPLAINT Page 17 1 THIRD CLAIM FOR RELIEF 2 PRIVATE NUISANCE (CALIFORNIA LAW) 3 C ALIFORNIA C IVIL C ODE § 3479 4 (Against Defendants So. Cal. Gas and Sempra) 5 6 7 73. Plaintiffs re-allege and incorporate the foregoing paragraphs as though fully set forth 74. Defendants’ failed to exercise reasonable care in the course of constructing, herein 8 operating, and/or maintaining their Aliso Canyon storage facility and injection wells and continue 9 to allow leaks, releases, emissions, and/or migration of pollutants to the surrounding area 10 including Plaintiffs’ properties. Defendants created a condition that is harmful to Plaintiffs’ 11 health and free use of their properties so as to seriously interfere with comfortable enjoyment of 12 their life and property, including creating conditions such that certain Plaintiffs had to physically 13 flee from their homes. Plaintiffs suffer from the ongoing contamination of the air surrounding 14 their homes and the threat of continued leaks, releases, emissions, and/or migration of pollutants 15 to the surrounding area including Plaintiffs’ property. 16 75. The continuing condition created by the Defendants harmed Plaintiffs. This harm 17 includes, but is not limited to, polluted land and air in and around Plaintiffs’ properties and 18 adverse health effects due to exposure. 19 76. Plaintiffs did not consent to Defendants’ conduct. 20 77. An ordinary person of reasonable sensibility would reasonably be annoyed and/or 21 22 disturbed by the conditions created by Defendants. 78. Defendants’ aforementioned conduct constitutes a nuisance within the meaning of 23 section 3749 of the Civil Code in that it is injurious to health and/or offensive to the senses of 24 Plaintiffs and/or unreasonably interferes with the comfortable enjoyment of Plaintiffs’ land and/or 25 the free and customary use of Plaintiffs’ property. 26 79. Defendants’ conduct, including constructing, operating, and/or maintaining the Aliso 27 Canyon storage facility and its injection wells was a substantial factor, and likely the only 28 cognizable factor, in causing the harm. Further, continuing harm remains due to the current and ________________________________________________________________________________ COMPLAINT Page 18 1 ongoing contamination of Plaintiffs’ properties. 2 80. The seriousness of Defendants’ conduct referenced above outweighs the public 3 benefits of the Defendants’ Aliso Canyon storage facility operations because gas leaks seriously 4 deprive Plaintiffs of peaceful enjoyment of their homes and pollute the air of the surrounding 5 properties and neighborhoods. In comparison, the social value and primary purpose of such 6 activity is the maximization of profit for corporations with no incentive to take precautions to 7 ensure the safety and environmental integrity of the storage facility. 8 81. Plaintiffs have no speedy, plain, or adequate remedy of law for the injuries presently 9 being suffered or for the aggravation of such injuries. Unless the nuisance created by Defendants 10 is restrained by a preliminary and permanent injunction, Plaintiffs will suffer great and irreparable 11 injury in that dangerous levels of noxious odors, hazardous gases, chemicals, pollutants, and 12 contaminants will continue to emanate from Defendants’ Aliso Canyon storage facility, pollute 13 the air, Plaintiffs’ properties, and continue to damage the right of Plaintiffs and their families to 14 live in their homes without harmful exposure. 15 82. Defendants actions resulted in the pollution of air and deprived residents of Porter 16 Ranch of their ability to live in their homes free of health problems. Defendants took these 17 actions with a willful and knowing disregard of the rights and safety of the community. Plaintiffs 18 should, therefore, be awarded punitive and exemplary damages under Civil Code section 3294 19 sufficient to punish Defendants for engaging in this conduct and to deter similar conduct in the 20 21 22 23 24 25 26 27 28 future. 83. As a further result of this wrongful conduct, Plaintiffs suffered, and will continue to suffer, the loss of the quiet use and enjoyment of its property in addition to all of their general damages in an amount to be set forth according to proof at trial. 84. In addition, Plaintiffs should be awarded attorney’s fees under Code of Civil Procedure section 1021.5 because the successful prosecution of this action will confer a significant benefit both pecuniary and non-pecuniary on the general public and a large class of persons by abating environmental harm and preventing future harm to residents of Porter Ranch. Further, the necessity and financial burden of private enforcement makes such an award appropriate as the litigation is not economically feasible or viable for Plaintiffs to pursue on their ________________________________________________________________________________ COMPLAINT Page 19 1 own at their own expense, and such fees should not in the interest of justice be paid out of the 2 recovery, if any. 3 FOURTH CLAIM FOR RELIEF 4 PUBLIC NUISANCE (CALIFORNIA LAW) 5 C ALIFORNIA C IVIL C ODE § 3480 6 (Against Defendants So. Cal. Gas and Sempra) 7 8 9 85. Plaintiffs re-allege and incorporate the foregoing paragraphs as though fully set forth 86. Defendants’ failed to exercise reasonable care in the course of constructing, herein. 10 operating, and/or maintaining the Aliso Canyon storage facility and injection wells, and continue 11 to allow noxious odors, hazardous gases, chemicals, pollutants, and contaminants to be leaked, 12 released, emitted or migrated to the surrounding areas including Plaintiffs’ properties. 13 Defendants created a continuing condition that is harmful to Plaintiffs’ health and free use of their 14 homes so as to seriously interfere with comfortable enjoyment of their life and property. 15 87. The continuing conditions created by the Defendants harmed residents in Porter 16 Ranch and the surrounding neighborhoods, and a substantial number of people at the same time. 17 The harmful condition includes pollution of the Plaintiffs’ land, homes, and persons from noxious 18 odors, hazardous gases, chemicals, pollutants, and contaminants emanating and/or migrating from 19 Defendants’ Aliso Canyon storage facility and injection wells. 20 88. Plaintiffs did not consent to the Defendants conduct. 21 89. Defendants’ aforementioned conduct constitutes a nuisance within the meaning of 22 section 3749 of the Civil Code in that it is injurious to health and/or offensive to the senses of 23 Plaintiffs and/or unreasonably interferes with the comfortable enjoyment of Plaintiffs’ properties 24 and/or the free use, in the customary manner, of Plaintiffs’ properties. 25 90. As a result of Defendants’ conduct, Plaintiffs suffered a type of harm that is different 26 from the type of harm suffered by the general public. Specifically, Plaintiffs have lost the use and 27 enjoyment of their land, including, but not limited to exposure to an array of pollutants in their 28 ________________________________________________________________________________ COMPLAINT Page 20 1 persons and on their land, and the continuing threat of leaks, releases, emissions, and/or migration 2 of dangerous levels of noxious odors, hazardous gases, chemicals, pollutants, and contaminants. 3 4 5 91. An ordinary person of reasonable sensibilities would be reasonably annoyed and/or disturbed by the condition created by Defendants. 92. The seriousness of Defendants’ conduct referenced above outweighs the public 6 benefits of the Defendants’ Aliso Canyon storage facility operations because gas leaks seriously 7 deprive Plaintiffs of peaceful enjoyment of their homes and pollute the air of the surrounding 8 properties and neighborhoods. In comparison, the social value and primary purpose of such 9 activity is the maximization of profit for corporations with no incentive to take precautions to 10 ensure the safety and environmental integrity of the storage facility. 11 93. Defendants’ conduct, including constructing, operating, and/or maintaining the Aliso 12 Canyon storage facility and its injection wells was a substantial factor, and likely the only 13 cognizable factor, in causing the harm. Further, continuing harm remains due to the current and 14 ongoing contamination of Plaintiffs’ properties. 15 16 17 94. Plaintiffs further allege that as a consequence of Defendants’ acts and/or failures to act, this public nuisance must be abated. 95. Plaintiffs have no speedy, plain, or adequate remedy of law for the injuries presently 18 being suffered or for the aggravation of such injuries. Unless the nuisance created by Defendants 19 is restrained by a preliminary and permanent injunction, Plaintiffs will suffer great and irreparable 20 injury in that dangerous levels of noxious odors, hazardous gases, chemicals, pollutants, and 21 contaminants will continue to emanate from Defendants’ Aliso Canyon storage facility, pollute 22 the air, Plaintiffs’ properties, and continue to damage the right of Plaintiffs and their families to 23 live in their homes without harmful exposure. 24 96. Defendants actions resulted in the pollution of air and deprived residents of Porter 25 Ranch of their ability to live in their homes free of health problems. Defendants took these 26 actions with a willful and knowing disregard of the rights and safety of the community. Plaintiffs 27 should, therefore, be awarded punitive and exemplary damages under Civil Code section 3294 28 sufficient to punish Defendants for engaging in this conduct and to deter similar conduct in the ________________________________________________________________________________ COMPLAINT Page 21 1 future. 2 97. As a further result of this wrongful conduct, Plaintiffs suffered, and will continue to 3 suffer, the loss of the quiet use and enjoyment of its property in addition to all of their general 4 damages in an amount to be set forth according to proof at trial. 5 98. In addition, Plaintiffs should be awarded attorney’s fees under Code of Civil 6 Procedure section 1021.5 because the successful prosecution of this action will confer a 7 significant benefit both pecuniary and non-pecuniary on the general public and a large class of 8 persons by abating environmental harm and preventing future harm to residents of Porter Ranch. 9 Further, the necessity and financial burden of private enforcement makes such an award 10 appropriate as the litigation is not economically feasible or viable for Plaintiffs to pursue on their 11 own at their own expense, and such fees should not in the interest of justice be paid out of the 12 recovery, if any. 13 FIFTH CLAIM FOR RELIEF 14 INVERSE CONDEMNATION (CALIFORNIA LAW) 15 C ALIFORNIA C ONSTITUTION A RT . I § 19 16 17 18 99. AND C IVIL CODE §3479 Plaintiffs re-allege and incorporate the foregoing paragraphs as though fully set forth herein. 100. On October 8, 2015, DOGGR admitted that upwards of 78% of the injection projects 19 in the Los Angeles area allowed injections without a full analysis of the impact and potential 20 migration of contaminants from injection wells (a process called the area of review). This 21 included a failure by DOGGR to consider how gas may enter into idle oil and gas wells nearby. 22 Of those some 22% of injection projects where an area of review was “completed”, almost 20% 23 of the wells reviewed were ultimately determined to not meet regulatory standards for zonal 24 confinement. (See Exhibit 2 – August 8, 2015 DOGGR SB855 Report Excerpt.) 25 101. Despite the pendency of a lawsuit against DOGGR for failure to protect Californians 26 from these illegally permitted wells, DOGGR continues to let So. Cal. Gas and other companies 27 operate injection wells that may harm the community. 28 102. On December 1, 2015, Plaintiffs’ sought relief directly from the DOGGR, ________________________________________________________________________________ COMPLAINT Page 22 1 demanding the cessation of further injection by Defendant So. Cal. Gas, the disclosure of all 2 chemicals detected in air quality tests as provided by So. Cal. Gas and other governmental 3 entities, and confirmation that no injection activities by other operators are impairing the ability of 4 Defendants to stop the leaking well. (See Exhibit 1 – December 1, 2015 Letter to State Oil & Gas 5 Supervisor.) 6 103. Plaintiffs in this action must now move from their homes – temporarily and perhaps 7 permanently. The acts and/or omissions of Defendants, collectively and each of them 8 individually, as alleged herein, have resulted in leaks, releases, emissions, and/or migration of 9 dangerous level of noxious odors, hazardous gases, chemicals, pollutants, and contaminants onto 10 Plaintiffs’ properties. In addition, the continued acts and/or omissions of Defendants, collectively 11 and each of them individually, as alleged herein, have resulted in ongoing leaks, releases, 12 emissions, and/or migration of dangerous level of noxious odors, hazardous gases, chemicals, 13 pollutants, and contaminants onto Plaintiffs’ properties. 14 104. Such acts and/or omissions of Defendants collectively and each of them individually, 15 as alleged herein, constitute a physical invasion of Plaintiffs’ real property for a public use, 16 placing a burden on Plaintiffs’ properties that is direct, substantial and peculiar to the properties 17 themselves. 18 105. Based on information and belief, Plaintiffs allege that at all times mentioned herein, 19 each and every Defendant was acting as an agent and/or employee of each of the other 20 Defendants, and at all relevant times mentioned was acting within the course and scope of said 21 agency and/or employment with the full knowledge, permission, and consent of each of the other 22 Defendants. In addition, each of the acts and/or omissions of each Defendant alleged herein were 23 made known to, and ratified by, each of the other Defendants. 24 106. As a direct and proximate result of Defendants’ acts and/or omissions, Plaintiffs 25 have suffered harm including, but not limited to, polluted land and air in and around Plaintiffs’ 26 property and adverse health effects due to exposure. 27 28 107. Defendants’ actions were a substantial factor in causing the harm to the Plaintiffs as there were no other independent causes of the physical invasion onto Plaintiffs’ properties. ________________________________________________________________________________ COMPLAINT Page 23 1 108. Wherefore, Plaintiffs request relief as hereinafter provided. 2 PRAYER FOR RELIEF 3 WHEREFORE, Plaintiffs request relief against Defendants as follows: 4 A. A judgment in favor of Plaintiffs on all claims; 5 B. An award to Plaintiffs for the amount of damages as proven at trial; 6 C. An award to Plaintiffs for punitive damages; 7 D. An immediate temporary injunction against Defendants to prevent further harm to 8 Plaintiffs and to include provisions for further ongoing monitoring of Plaintiffs’ 9 property and potential remediation by Defendants; 10 E. 11 For reasonable attorneys’ fees pursuant to California Code of Civil Procedure, section 1021.5; 12 F. For interest at the legal rate on all amounts awarded; 13 H. Such other and further relief as this Court may deem just and proper. 14 15 DEMAND FOR JURY TRIAL Plaintiffs hereby demand trial by jury on all issues triable of right by jury. 16 17 DATE: December 2, 2015 R. REX PARRIS LAW FIRM 18 19 20 21 Attorneys for Plaintiffs 22 23 24 25 26 27 28 ________________________________________________________________________________ COMPLAINT Page 24 EXHIBIT 43364 10th Street West Lancaster, California 93534 T: 661.949.2595 F: 661.949.7524 400 South Hope Street, Suite 1100 Los Angeles, California 90071 T: 310.824.5600 F: 661.949.7524 December 1, 2015 VIA E-MAIL AND OVERNIGHT EXPRESS John Laird, California Secretary for Natural Resources Natural Resources Agency 1416 Ninth Street, Suite 1311 Sacramento, CA 95814 David Bunn, Director of Department of Conservation California Department of Conservation 801 K Street, MS 24-01 Sacramento, CA 95814 Steve Bohlen, State Oil & Gas Supervisor California Department of Conservation Division of Oil, Gas, and Geothermal Resources 801 K Street, MS 18-05 Sacramento, CA 95814-3530 Re: Aliso Canyon Gas Leak Dear Secretary Laird, Director Bunn, and State Oil & Gas Supervisor Bohlen, Southern California Gas injects natural gas underground – the injection well activities led to the leaking of massive amounts of methane near families in Porter Ranch, a residential community in Los Angeles County. We represent Save Porter Ranch and members of the Porter Ranch community. Save Porter Ranch is demanding the State Oil & Gas Supervisor issue an emergency order requiring So. Cal. Gas to stop all injections in this oilfield by December 3, 2015. Public Resources Code sections 3013, 3106, 3224, 3326, 3300 and 3403.5 give the State Oil & Gas Supervisor this authority. Public Resources Code section 3235 mandates an investigation, written report, and order by the State Oil & Gas Supervisor on receipt of this complaint. DOGGR should have issued such an order weeks ago. As DOGGR knows, on or before October 23, 2015, So. Cal. Gas detected an uncontrolled flow of fluids and gas from one of its injection wells in the Aliso Canyon Oil Field. So. Cal. Gas attempted to “kill” the well by filling the well bore with heavy brine to stop gas from escaping. (See Attachment 1.) This plan failed. Additional attempts to kill the well with a barite solution also failed. (See Attachment 2.) With no other remedies available, So. Cal. Gas now seeks to drill a new well to overcome the reservoir pressure. (See Attachment 3.) This process will take three to four months, and there is no guarantee of success. LAWYERS PROTECTING YOU R. Rex Parris Robert A. Parris Alexander R. Wheeler Jason P. Fowler Bruce L. Schechter Kitty K. Szeto Patricia K. Oliver Ryan K. Kahl Breanna L. Kenyon John M. Bickford Naomi C. Pontious Jonathan W. Douglass Sean J. Lowe Eric N. Wilson Ethan T. Litney Bernadette N. Manigault Re: Aliso Canyon Gas Leak December 1, 2015 Page 2 Save Porter Ranch is also demanding the State Oil & Gas Supervisor immediately disclose all test data received from So. Cal. Gas regarding the chemicals being released. DOGGR’s November 18, 2015 Emergency Order required So. Cal. Gas to provide this data, and thus, DOGGR should immediately upload this information to the internet. DOGGR’s failure to provide this information only increases the concern that DOGGR may be protecting So. Cal. Gas at the expense of the residents of Porter Ranch. The injection well that is leaking is one of 154 injection wells in this oil field including 93 active gas storage wells. DOGGR’s prior emergency order did not order So. Cal. Gas to immediately stop injection activity in this field, and DOGGR’s failure to act is increasing the risk to the community. Indeed, there are 93 active gas storage wells injecting into the Sesnon-Frew reservoir, the same reservoir as well 03700776. (See Attachment 4, List of Aliso Canyon Injection Wells.) The risks are compounded because there are at least 22 gas storage wells that are idle and thus can serve as conduits (or straws) transporting the gas from one area to another. The most recent data shows that in one month So. Cal. Gas injected over 5.7 billion cubic feet of natural gas into the Sesnon-Frew reservoir. (See Attachment 5, DOGGR Gas Injection Data.) The difficulties faced by So. Cal. Gas in controlling the high-pressure leak in one injection well are surely exacerbated by any continued high-pressure injection of billions of cubic feet of natural gas into the same shared gas-storage reservoir. Of greater concern, the continued injections create a serious public health risk for the families in Porter Ranch. On October 8, 2015, DOGGR admitted that upwards of 78% of the injection wells in Los Angeles County allowed injections without protecting from the migration of the gas or waste into idle wells nearby. (See Attachment 6.) None of the injection wells appears to comply with the UIC regulations under 14 CCR 1724.7 and 1724.9 – including the lack of an area of review analysis required to ensure zonal isolation of injectate. DOGGR records also suggest that DOGGR has not required So. Cal. Gas to properly report all injection pressure as required by 14 CCR 1724.10. (See Attachment 5.) In addition to gas injection wells, there are 11 other injection wells operated by So. Cal. Gas in this oil field. These other injection wells include active waterflood and waste disposal wells. DOGGR also issued permits for these injection wells without requiring that So. Cal. Gas follow the UIC regulations protecting the public, and again, there is an incomplete record of injection pressure data. (See Attachment 7, DOGGR Water Injection Data.) In the rare instances where So. Cal. Gas reported injection pressure, it appears that these wells may be injecting wastewater at or above the formation fracture pressure. (See Attachment 3, p. 2 (So. Cal. Gas estimates that the formation fracture gradient is 0.80 psi/ft); Attachment 7 (demonstrating wastewater injection at 1,500 psi in a well with a top perforation at 3,764 feet); Attachment 8, Excerpt from June 2011 Horsley Witten Group DOGGR Class II UIC Program Review (discussing maximum allowable surface pressure calculation).) Given the unknown degree to which the Aliso Canyon formations have already been damaged, our clients request that DOGGR’s order blocking all injection activities also block water injection at least until So. Cal. Gas obtains control over the leaking gas. LAWYERS PROTECTING YOU R. Rex Parris Robert A. Parris Alexander R. Wheeler Jason P. Fowler Bruce L. Schechter Kitty K. Szeto Patricia K. Oliver Ryan K. Kahl Breanna L. Kenyon John M. Bickford Naomi C. Pontious Jonathan W. Douglass Sean J. Lowe Eric N. Wilson Ethan T. Litney Bernadette N. Manigault Re: Aliso Canyon Gas Leak December 1, 2015 Page 3 Other operators in this oilfield obtained injection well permits. It is unclear from DOGGR’s website whether any other injection wells are operational. DOGGR should also investigate what the other oil companies with operations in this oil field do with their waste water. Obviously it must be disposed of by these operators, and thus far, there are no records demonstrating disposal in properly permitted injection wells. DOGGR should confirm there are no other injection wells that could be impairing the ability of So. Cal. Gas to stop the leak. Let there be no mistake about the impact this leak is having on the families in Porter Ranch. Almost 300 families had to evacuate during this holiday season. The families in this community live here because it is supposed to be safe, and now it is not. Children and adults suffer from regular nosebleeds, headaches, nausea and vomiting. These families have a right to live without toxic poisoning of their neighborhood. The amount of methane being released from So. Cal. Gas’s gas injection well is estimated to be upwards of 50,000 kilograms of methane an hour, potentially accounting for a quarter of California’s total methane emissions every day the leak continues. (See Attachment 9, Air Resources Board Report.) Residents are afraid to open their windows, forced to perpetually run their air conditioners, and are finding oily residue in their swimming pools. In sum, Save Porter Ranch demands that DOGGR issue an order by December 3, 2015 that provides the following protections to the families of Porter Ranch: 1. So. Cal. Gas must cease all injections other than injections approved by DOGGR to stop the massive leak. 2. DOGGR must disclose all chemicals detected in air quality tests as provided by So. Cal. Gas and any government agency. 3. DOGGR must investigate and confirm no other injection activities by other operators are impairing the ability of So. Cal. Gas to stop the leaking well. If DOGGR fails to act, we plan to challenge DOGGR’s inaction and to seek all available damages for the personal injuries suffered and the taking of our Clients’ property rights in violation of the United States Constitution. Save Porter Ranch can be reached through its Counsel, R. Rex Parris Law Firm at 43364 10th Street West, Lancaster, California 93534. Sincerely, R. Rex Parris R. Rex Parris Law Firm Attorneys for Save Porter Ranch cc: Governor Edmund G. Brown (governor@governor.ca.gov) Attorney General Kamala D. Harris (attorneygeneral@doj.ca.gov) LAWYERS PROTECTING YOU R. Rex Parris Robert A. Parris Alexander R. Wheeler Jason P. Fowler Bruce L. Schechter Kitty K. Szeto Patricia K. Oliver Ryan K. Kahl Breanna L. Kenyon John M. Bickford Naomi C. Pontious Jonathan W. Douglass Sean J. Lowe Eric N. Wilson Ethan T. Litney Bernadette N. Manigault Re: Aliso Canyon Gas Leak December 1, 2015 Page 4 Eric Garcetti (mayor.garcetti@lacity.org) Mitchell Englander (councilmember.englander@lacity.org) John Geroch (john.geroch@conservation.ca.gov) Alan Walker (alan.walker@conservation.ca.gov) Southern California Gas Company LAWYERS PROTECTING YOU R. Rex Parris Robert A. Parris Alexander R. Wheeler Jason P. Fowler Bruce L. Schechter Kitty K. Szeto Patricia K. Oliver Ryan K. Kahl Breanna L. Kenyon John M. Bickford Naomi C. Pontious Jonathan W. Douglass Sean J. Lowe Eric N. Wilson Ethan T. Litney Bernadette N. Manigault ATTACHMENT 1 COMMUNITY AWARENESS ALISO CANYON STORAGE FACILITY UPDATE NOVEMBER 12, 2015 BACKGROUND On October 23, SoCalGas crews discovered a leak at one of the natural gas storage wells at our Aliso Canyon storage field. After conducting our normal procedures to stop the leak, we realized that additional expertise and equipment were needed in this situation. We brought in a team of world-class experts to help us, and have since been working as quickly as safety will allow, to stop the leak. CONTENT 1 Aliso Canyon Natural Gas Background 2 Situation Update 2 Health Questions We have been working closely with all of the appropriate public agencies, including the L.A. City and County Fire Departments and Hazmat Departments, the L.A. County Department of Health, the California Division of Oil, Gas & Geothermal Resources, and the South Coast Air Quality Management District. 2 Claims Information We sincerely apologize for any concern this odor is causing the neighboring communities. However, the leak does not pose an imminent threat to health or public safety. The well is located in an isolated, mountain area more than a mile away from and more than 1,200 feet higher than the closest home or public area. Scientists agree natural gas is not toxic and that its odorant is not toxic at the minute levels at which it is added to natural gas. Health and air-quality officials said that the levels of the additive found in air samples taken in Porter Ranch should not pose a health problem. 3 Well Diagrams “WE ARE SORRY FOR THE CONCERNS THE LEAK AND ITS ODOR MAY HAVE CAUSED YOU. WE ARE COMMITTED TO WORKING AS QUICKLY AS SAFETY WILL ALLOW TO STOP THE FLOW OF NATURAL GAS” 1 2 SoCalGas’ Commitment to the Environment 4 Progress Timeline 4 Contact Information SITUATION UPDATE As of Wednesday November 11, SoCalGas’ team of well management experts have cleared the ice blockage in the well and completed a multi-day operation of successive probes and tests. We have collected and analyzed all available data obtained during the diagnostics, and we are now preparing and planning our approach to stop the flow of gas. We have some of the world’s best experts advising us, and they owe their success to their HEALTH QUESTIONS CLAIMS INFORMATION Once again, we apologize to our neighbors and residents who may be affected by the odor of natural gas. Although natural gas is not considered to be toxic or a hazardous air pollutant, it does smell bad. Odors affect everyone differently and some people may feel ill from the smell. We encourage people to call a doctor if they feel they need to. We apologize for any discomfort the odors may be causing you or your family. If you believe you have suffered harm or injury as a result of this incident, please call 213-244-5151 to speak to a claims representative. To help provide the public with more information, we are taking air samples regularly. The results are posted on socalgas.com. You can also download a Claims Form at: socalgas.com/about-us/our-services/ consulting/claims.shtml Mail or fax the form to: Southern California Gas Company Attention: Claims Department P. O. Box 60980 Los Angeles, California 90060-0980 Fax number 213-244-8214 cautious approach. The leak site remains safe because it’s in a localized area more than a mile If you have health questions you can contact the L.A. County Department of Health at (888) 700-9995. away from homes and businesses. Natural gas continues to leak from the pipe casing and is seeping from the ground areas near the well; however, it is not blowing at high pressure. SOCALGAS’ COMMITMENT TO THE ENVIRONMENT We are committed to resolving the situation quickly, not only to alleviate our neighbors’ concern, but also to reduce the environmental impact. We’re working hard to reduce the flow of natural gas and stop the leak as quickly as possible. Reducing what are called “fugitive emissions” that contribute to climate change has been an extremely high priority for SoCalGas for many years. As a result, our distribution system has one of the lowest fugitive emissions rates in the country. We genuinely care about the environment, and we are presently working with our team of experts and regulatory agencies to reduce the impact of the leak to the environment and surrounding community. Once the leak is stopped, we will work with the appropriate agencies to evaluate and address the environmental impact of this leak. 2 Coiled Tubing Surface Casing Coiled Tubing Tubing 2 7/8” diameter Surface Casing 11” diameter Well Pipe Casing 7” diameter Ground level to Natural Gas Deposit ~8,500 ft Tubing 2 7/8” diameter Brine Solution Ground level to Natural Gas Deposit ~8,500 ft Natural Gas Well Pipe Casing 7” diameter Cap Rock Natural Gas Reservoir Cap Rock Natural Gas Reservoir FIGURE 1 FIGURE 2 Natural Gas Well Leak Indicators are that natural gas is leaking from the well pipe casing into the ground near the well. Current Efforts to Remedy the Leak The goal is to fill the well pipe with enough brine solution to stop the flow of natural gas. SoCalGas’ team of experts will fill the well pipe with enough brine solution to out weigh the pressure of the natural gas, thus stopping the flow of the natural gas from the leak. * Graphic is for informational purposes only. Scale and technical detail are not accurate. 3 N ov Pr 7og 11 Dia ress gn ive os Se tic ri Te es sts of Ne N Co ighb ov un or 4 cil ho Me od et ing ch Ra n te r Po r St an Ad st dar dit op d p O ion le ro ct al ak ced 2 ex no ur 4 pe t e es rti ffe to se ct ca ive We lle . di ll T n. es O tin c g& t 2 Dia 6gn 30 os tic s Oc Le t 23 ak Eq Dis uip co me ver e Oc nt M d. C o re t We 25 biliz ws ed & ll e . xp er ts on sc en e Oc t Co 31 ile Ru d Tu No n, bi v Br ng 6 ea Ri kT g– hr P u I re ce p, T es t, ALISO CANYON SITUATION TIMELINE SoCalGas will continue to keep the community updated by posting updates and information on our website socalgas.com under the title “Aliso Canyon Updates.” We have also set up a special call-in number (818) 435-7707 and email address, AlisoCanyon@socalgas.com, where customers can contact us. In addition, we welcome neighbors to stop by our public information booth, open 7 days a week from 10 a.m. to 5 p.m., near the entrance to our facility 12801 Tampa Avenue. Thank you to our customers and the community for your cooperation, patience and understanding. socalgas.com 1 800-427-2200 © 2015 Southern California Gas Company. All copyright and trademark rights reserved. N15K0111A 11152015 ATTACHMENT 2 1 2 3 4 Department of Conservation, Division of Oil, Gas, and Geothermal Resources Legal Office for the STATE OIL AND GAS SUPERVISOR 801 K Street, MS 24-03 Sacramento, California 95814-3530 Telephone (916) 323-6733 Facsimile (916) 445-9916 5 6 7 8 9 10 11 12 13 14 15 16 STATE OF CALIFORNIA NATURAL RESOURCES AGENCY DEPARTMENT OF CONSERVATION DIVISION OF OIL, GAS, AND GEOTHERMAL RESOURCES EMERGENCY ORDER TO: PROVIDE DATA RE: ALISO CANYON GAS STORAGE FACILITY [Pub. Resources Code, §§ 3106, 3224, 3226, 3300, and 3403.5.] [Cal. Code Regs., tit. 14, §§ 1724.6, 1724.7, subd. (e), and 1724.10, subs. (a), (h) & (k)] 17 18 19 20 21 22 Emergency Order No. 1104 November 18, 2015 Operator: Southern California Gas Company (S4700) Aliso Canyon Field Los Angeles County 23 24 25 26 BY Dr. Steven R. Bohlen STATE OIL AND GAS SUPERVISOR 27 28 1 Emergency Order No. 1104; Provide Data Re: Aliso Canyon Storage Facility 1 I. Introduction The State Oil and Gas Supervisor (Supervisor), acting under the authority of the Public 2 3 Resources Code (PRC), including PRC section 3224, can order tests and remedial work 4 concerning oil field operations which, in his judgment, are necessary to prevent damage to life, 5 health, property, and natural resources. (See Pub. Resources Code, §§ 3106 and 3224.) In 6 addition, under the PRC, the Supervisor is charged with ensuring that “no damage occurs to the 7 environment by reason of injection and withdrawal of gas” in underground gas storage facilities. 8 (Pub. Resources Code, § 3403.5.) To that end, the Supervisor has the authority to request any 9 data that are pertinent and necessary for the Division of Oil, Gas, and Geothermal Resources 10 (Division), and its District Deputy, to properly evaluate underground injection projects (See, 11 e.g., Cal. Code Regs., tit. 14, §§ 1724.6 and 1724.7, subd. (e).) The operator of an injection 12 project must maintain these data to show, among other things, that no damage to life, health, 13 property, or natural resources is occurring by reason of the project (Cal. Code Regs., tit. 14, § 14 1724.10, subd. (h)) and such data must be made available for inspection by Division personnel 15 (Ibid.). Moreover, in an emergency, “the [S]upervisor may order or undertake the actions he or 16 she deems necessary to protect life, health, property, or natural resources.” (Pub. Resources 17 Code, § 3226.) At all times relevant to this Order, Southern California Gas Company1 (SoCal Gas or 18 19 Operator) is the “operator,” as defined in PRC section 3009, of certain “wells,” as defined in 20 PRC section 3008, subdivision (a), and is conducting “operations” as defined in California Code 21 of Regulations, title 14, (Regulations) section 1720, subdivision (f), at a gas storage project (see 22 Cal. Code Regs., tit. 14, § 1724.9) in the Aliso Canyon Field in Los Angeles County (Field). 23 Based on data in the files of the Division, discussions with operator, and Division site 24 visits, the Supervisor has determined that that there is an uncontrolled flow of fluids (see 25 1722.5) from well “Standard Sesnon” 25, and a waste of gas, in the Field that Operator has been, 26 and is currently, addressing. Operator’s efforts to address the upset have included various tests 27 1 28 The Operator Code the Division uses for Southern California Gas Company is S4700. 2 Emergency Order No. 1104; Provide Data Re: Aliso Canyon Storage Facility 1 and remedial work. However, the efforts have not yet remedied the uncontrolled flow of fluids 2 or stop the waste of gas. In addition, Operator has not yet furnished the Division information 3 about, and results from, some of the tests and/or remedial work. The Supervisor needs 4 immediate access to these data to monitor and address the uncontrolled flow of fluids, and 5 current and future remedial work. Therefore, according to PRC sections 3013, 3106, 3224, 6 3226, 3300, and 3403.5, and Regulations sections 1724.6, 1724.7, subdivision (e), and 7 1724.10, subdivisions (a), (h), and (k), the Supervisor hereby orders Operator to provide 8 the data identified below (Section V; Data Required from Operator). 9 10 11 12 13 II. Definitions The following definitions apply to the terms used in this Order: PRC section 3008, subdivision (a), defines “Well” to mean, among other things, “any well drilled for the purpose of injecting fluids or gas for stimulating oil or gas recovery[.] PRC section 3009 defines “Operator” to mean “a person who, by virtue of ownership, 14 or under the authority of a lease or any other agreement, has the right to drill, operate, maintain, 15 or control a well or production facility.” 16 Regulations section 1720, subdivision (f), defines “Operations” to mean “any one or all 17 of the activities of an operator covered by Division 3 of the Public Resources Code [i.e., the oil 18 and gas law, commencing with PRC section 3000].” 19 20 III. Statutory and Related Authority PRC section 3013 states that the oil and gas law (Division 3 of the PRC, commencing 21 with section 3000) “shall be liberally construed to meet its purposes” and grants the Supervisor 22 “all powers” that may be necessary to carry out those purposes. 23 PRC section 3106, subdivision (a), authorizes the Supervisor to “supervise the drilling, 24 operation, maintenance, and abandonment of wells and the operation, maintenance, and removal 25 or abandonment of tanks and facilities attendant to oil and gas production … so as to prevent, as 26 far as possible, damage to life, health, property, and natural resources[.]” 27 28 3 Emergency Order No. 1104; Provide Data Re: Aliso Canyon Storage Facility 1 PRC section 3224 requires the Supervisor to “order such tests or remedial work as in his 2 judgment are necessary to prevent damage to life, health, property, and natural resources[.]” 3 PRC section 3226 states that “Notwithstanding any other provisions of Section 3224, 4 3225, or 3237, if the supervisor determines that an emergency exists, the supervisor may order 5 or undertake the actions he or she deems necessary to protect life, health, property, or natural 6 resources.” 7 8 9 PRC section 3300 states, in part, that “[t]he blowing, release, or escape of gas into the air shall be prima facie evidence of unreasonable waste.” PRC section 3403.5 states, in part, that “The supervisor is required to maintain 10 surveillance over [underground gas storage] facilities to insure that the original reserves are not 11 lost, that drilling of new wells is conducted properly, and that no damage occurs to the 12 environment by reason of injection and withdrawal of gas. 13 Regulations section 1724.6 allows the Supervisor to require from an operator “any data 14 that, in the judgment of the Supervisor, are pertinent and necessary for the proper evaluation of 15 the proposed project.” 16 Regulations section 1724.7, subdivision (e), requires the following, where applicable: 17 “Other data as required for large, unusual, or hazardous projects, for unusual or complex 18 structures, or for critical wells. Examples of such data are: isogor maps, water-oil ratio maps, 19 isobar maps, equipment diagrams, and safety programs.” 20 Regulations section 1724.10, subdivision (a), requires that any changes to an injection 21 project “shall not be carried out without Division approval.” 22 Regulations section 1724.10, subdivision (h), states: “Data shall be maintained to show 23 performance of the [injection] project and to establish that no damage to life, health, property or 24 natural resources is occurring by reason of the project. Injection shall be stopped if there is 25 evidence of such damage … or upon written notice from the Division. Project data shall be 26 available for periodic inspection by Division personnel.” 27 28 4 Emergency Order No. 1104; Provide Data Re: Aliso Canyon Storage Facility 1 Regulations section 1724.10, subdivision (k), authorizes the Supervisor to request 2 additional data requirements or modifications as necessary to fit specific circumstances and 3 types of projects. 4 IV. Reasons Why Data Requested is Pertinent and Necessary 5 Operator’s efforts to address the uncontrolled flow of fluids have included various tests and 6 remedial work. However, the efforts have not yet remedied the uncontrolled flow of fluids nor 7 stopped the waste of gas. In addition, Operator has not yet furnished the Division with all 8 information about, and results from, some of the tests and/or remedial work. In order to ensure 9 that all necessary steps are taken to prevent damage to life, health, property, or natural resources, 10 the Supervisor needs immediate access to these data to monitor the uncontrolled flow of fluids 11 and current and planned activities to stop the uncontrolled flow of fluids and waste of gas. 12 13 V. Data Required from Operator Based on the facts, and in accord with the legal authorities, described in this Order, the 14 Supervisor has determined that he needs immediate access to the below data to monitor and 15 address the uncontrolled flow of fluids and waste of gas at Operator’s gas storage injection 16 project in the Field. Therefore, IT IS HEREBY ORDERED, pursuant to PRC sections 17 3013, 3106, 3224, 3226, 3300, and 3403.5, and Regulations sections 1724.6, 1724.7, 18 subdivision (e), and 1724.10, subdivisions (a), (h), and (k), that the Operator: 19 20 (A) By 5:00 p.m. Thursday November 19, 2015, provide continuous access to real- 21 time electronic monitoring of wellhead pressures, and, as requested by the Division, plans 22 and results of all diagnostic tests and well logs. 23 24 (B) By 5:00 p.m. Thursday November 19, 2015, submit the following information 25 obtained between Friday, October 23, 2015, and Wednesday, November 18, 2015: 26 27 28 1. Downhole videos; 5 Emergency Order No. 1104; Provide Data Re: Aliso Canyon Storage Facility 1 2. Well Logs, including temperature surveys, acoustic logs, neutron logs, cement 2 bond logs, ultra-sonic imager/gamma ray logs, density logs, nuclear fluid density 3 logs; 4 3. Pressure Surveys; 5 4. Pressure testing of the casings, tubing, and/or packers; and 6 5. Spinner Surveys. 7 8 (C) 9 relief well site preparation will be complete and when drilling of relief well will 10 By 5:00 p.m. Friday November 20, 2015, submit a time schedule identifying when commence. 11 12 13 Send all data via electronic mail to the Division (Alan Walker and John Geroch) at the following addresses: 14 Alan.Walker@conservation.ca.gov 15 John.Geroch@conservation.ca.gov 16 17 VI. Operator’s Appeal Rights 18 Operator may appeal this Order to the Director of the Department of Conservation by 19 filing a written notice of appeal with the Supervisor as described in PRC section 3350. (The 20 Legal Office for the State Oil and Gas Supervisor [801 K Street, MS 24-03, Sacramento, 21 California 95814-3530; Facsimile (916) 445-9916] will accept appeal notices on the 22 Supervisor’s behalf). Because this is an emergency order issued under PRC section 3226, the 23 filing of an appeal of this Order will not operate as a stay of this Order. (PRC, § 3350, subd. 24 (b)(1).) Failing to file a notice of appeal within the timeframe prescribed in PRC section 3350, 25 subdivision (a), waives Operator’s right to challenge this Order and makes the Order final. If 26 Operator timely files a notice of appeal, Operator will be informed of the appeal hearing date, 27 28 6 Emergency Order No. 1104; Provide Data Re: Aliso Canyon Storage Facility 1 time, and place. After the close of the hearing, Operator will receive a written decision that 2 affirms, sets aside, or modifies the Order. 3 4 VII. Court Order and Other Potential Actions to Enforce This Order Failing to comply with Section V (Data Required from Operator) of this Order could 5 subject Operator to further enforcement action. For example, the Supervisor could deny 6 approval of proposed well operations until compliance is achieved, order the plugging and 7 abandonment of wells, and/or assess a civil penalty. (Pub. Resources Code, §§ 3203, subd. (c), 8 3236.5, and 3237, subd. (a)(3)(C).) 9 Further, PRC section 3236 makes it a misdemeanor to fail, neglect, or refuse to furnish 10 any report or record that the Supervisor may require under the oil and gas law. The 11 misdemeanor is punishable by a fine of not less than one hundred dollars ($100) nor more than 12 one thousand dollars ($1,000), or by imprisonment not exceeding six months, or by both the fine 13 and imprisonment for each separate offense. PRC section 3359 makes it a misdemeanor to fail 14 or neglect to comply with an order of the Supervisor or to fail, refuse, or neglect to produce 15 books, papers, or documents as demanded in the order. Each day’s further failure, refusal, or 16 neglect is a separate and distinct offense. 17 18 DATED: November 18, 2015 19 20 21 Dr. Steven R. Bohlen State Oil and Gas Supervisor 22 23 24 25 26 27 28 Certified mail receipt number: 7012 1010 0000 9269 9029 7 Emergency Order No. 1104; Provide Data Re: Aliso Canyon Storage Facility ATTACHMENT 3 -- USE {Bond . comm,- .54- NATURAL RESOURCES AGENCY OF CALIFORNIA DEPARTMENT OF CONSERVATION DIVISION OF OIL, GAS, AND GEOTHERMAL RESOURCES OIL GAS 5 GF OTHERMAL 01 00 Detailed instructions can be found at: NOTICE OF INTENTION TO DRILL NEW WELL . Ctr"; in compliance with Section 3203, Division 3, Public Resources Code, notice is hereby given that it is our intention to drill well "Porter" 39A - well type Storage Well APJ No. 7 (Assigned by Division) Sec- 28 .T-3N .R. 16W . S.B. Aliso Canyon Storage Field, Los?Angelcs County. Legal description of mineralvright lease, consisting of acres (attach map 01? Plat 10 Scale): is as IOHOWSI Do mineral and surface leases coincide? ?YesIZl Nolj. If answer is no, attach legal description of both surface and mineral leases, and map or plat to scale. Location of well feet along section El I property line and feet (Check one) (Direction) at right angles to said line from the corner of section property and . (Check one} . Lat/Long. in decimal degrees, to six decimal places, NAD 83.format: Latitude: 34.312570 . Longitude: 418560352 if well is to be directionally drilled, show proposed coordinates (from surface location) and true vertical depth at total depth: 950 feet North and 1110 feet West . Estimated true vertical depth 7800 . Elevation of ground (Direction) (Directionl above sea level 2602 feet. All depth measurements taken from top of Kelly Bushing that is 22.5 feet above ground. (Derrick Floor. Rotary Table. or Kelly Bushing) Is this a critical well as de?ned in the California Code of Regulations, Title 14, Section 1720(a) (see next page)? YesE] No is a California Environmental Quality Act (CEQA) document required bye-?local agency?'YesD No Iii?yessee heritage?" PROPOSED CASING PROGRAM m, 2 t. 5? {inches (Estlmated Maximum) 13-3/8" 54.5# Surface 1200' Surface Hydrostatic 1200? 9-5/8" 47# Surface 7900' Surface Hydrostatic 7900? 7" 26# L-SO 7800' 8200' 7800'?8200' Variable-Storage - . 400' (Attach a complete drilling program including wellbore schematics in addition to the above casing program.) Estimated depth of base of fresh water: Anticipated geological markers: 8182' (Name, depth) intended zone(s) of completion: Sesnon - Storage Zone- Variable Estimated total depth: 8200' MD (Name, depth and expected pressure The Division must be noti?ed immediately of changes to the proposed operations. Failure to provide a true and accurate representation of the well and proposed operations may cause rescission of the permit. Name of Operator Southern California Gas Company A Address City/State Zip Code ?7 7 7 ?Northridge,?CK Name of Person Flling Notice Telephone Number: Signature Date Todd Van de Putte 661-305-5387 K, y, 11-19-15 individual to contact for technical questions: Telephone Number: E-Mail Address: Todd Van de Putte 661-305?53 87 This notice and an indemnity or cash bond shall be ?led, and approval given, before drilling begins. lf operations have not commenced within one year of the Division?s receipt of the notice, this notice will be considered cancelled. 06105 (08/09) Rec'd 11-19-15 DOGGR DZ Ventura Southern California Gas Companv - Aliso Canvon Porter 39A Drilling/Completion Program DATE: November 17, 2015 revised November 19, 2015 OBJECTIVE: Drill and complete a storage/intercept well in the Aliso Canyon Storage Field I SURFACE LOCATION: 28 Section, Township 3N, Range 16W, S.B. GPS Coordinates 83, Zone 5): 118560352 West 34.312570 North; API NUMBER: TBD DRILLING RIG: Ensign #587 (See attached proposed Rig Equipment List) Note: Drilling rig main power to use two 1500 hp low emission?natural gas ?red generators with one diesel generator backup. ELEVATIONS: Estimated Rig KB: 22.5? A All? to proposed kelly bushing 225? above ground elevation. HOLE COORDINATES (Preliminarv Directional Plan. Final to be Submitted): Bottom Hole Target: 8000? MD, 7800? TVD, 950? North, 1110? West Note: Another attempt to run a gyro survey in the Standard Sesnon 25 well will be made. An attempt to run a HVro survev in the Standard Sesnon 25 well was made on 11?10-15 and was unsuccessful due to the wellbore conditions at that time. I - TOP OF ZONES (Estimated. Measured Depth): MP: 8182? MD FORMATION FRACTURE GRADIENT (Estimated): 0.80 psi/ft FIELD PRESSURE: Sesnon Storage Zone: Variable BHP hydrostatic maximum bottom hole pressure (8.6- 9.2 mud planned, adjust mud weight according to actual storage zone pressure to maintain overbalance) Rec'd 11-19-15 DOGGR D2 Venture So Cal Gas Porter 39A Drilling/Completion Program PROPOSED CASING PROGRAM See attached wellbore schematic): 0? 1200? 13-3/8? 54.5# K-55, Buttress, Surface casing, cemented to surface. 0? 7900? 9-5/ 8? 47.0# L-80, Hydril 563, Production Casing cemented to surface 7800?? 8200? 7? 26# Liner (contingency) PROPOSED HOLE SIZES 0? to 1200? -- 17-12? hole 1201? to 7900? -- 14? hole. 7901? to 8200? 8?1/2? hole. DIRECTIONAL PROGRAM: (Final directional plan to follow Drill vertical hole to 2000? MD 2000? TVD. Directionally Drill 14? hole from 2001? to MD. Directionally Drill 8?1/2? hole from 7901? MD to MD. Estimated Total Measured Depth: MD. MUD PROGRAM: drilling to the casing shoes at- and-- (Holy-1136 thee-GEO Drilling -- -- -- w/3 Potash mud with the following properties: 9.6 Viscosity: 45 55 sec. A.P.I. Yield Point: 15-25 lb/ 100 sqft. em Fluid loss: 8 - 10 cc/ 30 min. A.P.I. solids: 3?7 pH: 9.0?9.5 4 Estimated static temperatures: 80 deg 1200?; 150 deg 7000?; 185 deg 8600? MD NOTES: 0 Add the equivalent of 13% to inhibit clay swelling while drilling in the producing zones. 0 Use sized calcium carbonate as required to control mud losses below the 9-5/ 8? production casing shoe. - Solids Control: a Mud cleaner with 150-200 mesh (API) screens and a Centrifuge will be onsite? during the drilling operations. Run the Mud Cleaner and. the Centrifuge to? maintain a high gravity solids content in the mud of less than bottomhole pressure. 0 Hydraulics to be based on a 120-160 ft/min annular velocity. ATTACHMENT 4 Operator Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Lease Standard Sesnon  Sesnon Fee  Sesnon Fee  Frew  Frew  Frew  Frew  Fernando Fee  Fernando Fee  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Porter  Porter  Fernando Fee  Fernando Fee  Fernando Fee  Porter  Porter  Fernando Fee  Standard Sesnon  Standard Sesnon  Porter  Porter  Porter  No. 29  1  3  2  4  5  7  32  33  14  14  25R  30  32  34  35  36  37  38  39  40  44  46  42  2  3  4  5  6  8  9  11  14  16  25  31  44  32B  32A  35E  35C  32F  26E  26D  32E  25A  25B  26C  32F  32D  API No. 03700041  03700647  03700649  03700665  03700667  03700668  03700670  03700686  03700687  03700703  03700703  03700712  03700717  03700719  03700721  03700722  03700723  03700724  03700725  03700726  03700727  03700731  03700733  03700753  03700755  03700756  03700757  03700758  03700759  03700761  03700762  03700763  03700766  03700768  03700776  03700781  03700788  03721276  03721277  03721278  03721279  03721313  03721319  03721320  03721321  03721322  03721323  03721353  03721354  03721355  Well Status Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Well Type Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Pool Name Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Porter‐Del Aliso A‐36  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Operator Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Lease Fernando Fee  Porter  Fernando Fee  Fernando Fee  Porter  Standard Sesnon  Porter  Porter  Standard Sesnon  Fernando Fee  Standard Sesnon  Fernando Fee  Fernando Fee  Fernando Fee  Porter  Porter  Porter  Fernando Fee  Porter  Porter  Standard Sesnon  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Porter  Fernando Fee  Fernando Fee  Fernando Fee  Porter  Porter  Porter  Standard Sesnon  Sesnon Fee  Frew  Frew  Frew  Mission Adrian  Mission Adrian  Porter  No. API No. 32D  26B  32B  32C  32C  44B  26A  32E  4A  35D  44A  35A  35B  32‐A  42A  42B  42C  34‐A  37‐A  69A  4‐0  50A  68A  69B  69C  69D  68B  69E  24A  24B  72A  72B  69H  69J  69G  69F  38A  38B  38C  69K  50B  46A  10  8  6  8  9  3  4  12  03721356  03721357  03721358  03721359  03721360  03721361  03721362  03721363  03721375  03721453  03721455  03721457  03721458  03721872  03721876  03721877  03721878  03722044  03722046  03722051  03722063  03722737  03722742  03724127  03724128  03724130  03724136  03724138  03724143  03724144  03724145  03724146  03724223  03724224  03724225  03724226  03724230  03724231  03724232  03724236  03724336  03724137  03700040  03700654  03700669  03700671  03700672  03700693  03700694  03700701  Well Status Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Active  Cancelled  Idle  Idle  Idle  Idle  Idle  Idle  Idle  Idle  Well Type Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Pool Name Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Operator Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  The Termo Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  The Termo Co.  Southern Calif. Gas Co.  Porter Sesnon et al  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Lease Porter  Porter  Porter  Standard Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Standard Sesnon  Mission Adrian  Mission Adrian  Standard Sesnon  Fernando Fee  Ward  Porter  Fernando Fee  Fernando Fee  Standard Sesnon  Porter  Porter Fee  Porter Fee  Porter Fee  Del Aliso 1  Frew  Fernando Fee  Fernando Fee  Fernando Fee  Mission Adrian  Porter  Porter  Porter  Porter  Porter  Standard Sesnon  Mission Adrian  Del Aliso 1  Fernando Fee  Porter  Porter  Porter  Fernando Fee  Del Aliso 1  Fernando Fee  Limekiln  Mission‐Adrian Fee  Mission‐Adrian Fee  Porter  Porter  Porter  Porter  No. API No. 26  45  47  1  12  13  17  24  30  1A  1B  1‐0  34BR  3A  50C  32G  32H  4B  39A  1  2  3  1  3  31  34  35  5  4  41  41  42  43  7  5‐A  4  37  24  33  50  36  6A  30  1  1  2  23  24  50  52  03700713  03700732  03700734  03700754  03700764  03700765  03700769  03700775  03700780  03721891  03721892  03722058  03722302  03722306  03724337  03730374  03730456  03730460  03730471  03700644  03700645  03700646  03700655  03700666  03700685  03700688  03700689  03700695  03700699  03700728  03700728  03700729  03700730  03700760  03722309  03700034  03700011  03700711  03700720  03700735  03706293  03700659  03700684  03700640  03700691  03700692  03700710  03700711  03700735  03700737  Well Status Idle  Idle  Idle  Idle  Idle  Idle  Idle  Idle  Idle  Idle  Idle  Idle  Idle  Idle  New  New  New  New  New  Plugged  Plugged  Plugged  Plugged  Plugged  Plugged  Plugged  Plugged  Plugged  Plugged  Plugged  Plugged  Plugged  Plugged  Plugged  Plugged  Idle  Active  Active  Active  Active  Active  Idle  Idle  Plugged  Plugged  Plugged  Active  Active  Active  Active  Well Type Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Gas Storage  Pressure Maintenance  Water Disposal  Water Disposal  Water Disposal  Water Disposal  Water Disposal  Water Disposal  Water Disposal  Water Disposal  Water Disposal  Water Disposal  Water Flood  Water Flood  Water Flood  Water Flood  Pool Name Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Aliso, West  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Sesnon‐Frew  Porter‐Del Aliso A‐36  Porter‐Del Aliso A‐36  Porter‐Del Aliso A‐36  Porter‐Del Aliso A‐36  Porter‐Del Aliso A‐36  Porter‐Del Aliso A‐36  Porter‐Del Aliso A‐36  Porter‐Del Aliso A‐36  No Pool Breakdown  Porter‐Del Aliso A‐36  Porter‐Del Aliso A‐36  Porter‐Del Aliso A‐36  Porter‐Del Aliso A‐36  Porter‐Del Aliso A‐36  Aliso  Operator Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Southern Calif. Gas Co.  Lease Porter  Porter  Porter  Porter  No. 53  73  19  22  API No. 03700738  03720642  03700708  03700709  Well Status Active  Active  Idle  Idle  Well Type Water Flood  Water Flood  Water Flood  Water Flood  Pool Name Aliso  Porter‐Del Aliso A‐36  Aliso  Porter‐Del Aliso A‐36  ATTACHMENT 5 Well Info ?ask Data Graph .I Grant naia Erlandlx API: open lSouthern Calif. Gas Co. I s4700 ?giggly County: @1194! W1 Field: lAllso Canyon I I 010 I Lease: [Porter I ?611*: HID. 5mm Area: [My Area I WJ District: Section: Twn: Rng: BM: pool; I Sesnon?Frew Entry: 2/2012 0.1/2012 2/2011 09/2015 08/2015 07/2015 06/2015 05/2015 04/2015 03/2015 02/2015 01/2015 12/2014 11/2014 10/2014 09/2014 08/2014 07/2014 06/2014 05/2014 04/ 2014 03/2014 02/2014 01/2014 11/2013 10/2013 09/2013 08/2013 07/2013 06/2013 05/2013 04/2013 03/2013 02/2013 01/2013 11/2012 10/2012 09/2012 08/2012 07/2012 06/2012 05/2012 04/2012 03/2012 02/2012 11/2011 12/2013 ?30 I wen Type: wen Pool Status: .. 00 218,438 26 2706 00 199,306 19 2639 00 194,414 24 2602 00 132,426 24 2592 00 279,648 30 2587 00 371,204 30 2383 00 183,575 21 2134 294,373 20 0 00 0 209,964 22 0 00 0 73,851 12 00 0 39,343 22.4 00 0 53,637 14 00 0 66,553 25 0 00 0 332,356 29 0 00 0 152,767 17 00 0 93,906 12 0 00 0 172,250 15 0 00 0 395,238 30 0 00 0 126,625 232,371 15 A ?0 00 0 50,530 15 0 00 0 35,591 15 00 0 14,349 2 00 0 115,416 23 0 0 4:34:41 Well Info - 03721359 . Southern Calif. Gas Co. API. Oper. I '54700 status: Field: lAliso Canyon [010 I Lease: [Fernando Fee Area: I Any Area I District: P001: I Sesnon?Frew Entry: Pool Status: . H30 I me: wen status: Active - .. 49:1. 09/2015 00 0 223,680 2 08/2015 00 0 100,301 - 07/2015 06 0 06/2015 00 0 131,275 2 05/2015 00 0 305,071 3 04/2015 00 0 404,949 3 03/2015 00 0 199,330 2 02/2015 06 0 0 - 01/2015 00 0 3,004 1-3 gm Hawk": 00 0 14,301 4 11/2014 00 0 23,779 10/2014 00 0 257,287 2 09/2014 06 0 0 - 08/2014 06 0 0 1 07/2014 00 0 331,234 2 06/2014 00 0 462,834 3 05/2014 00 0 493,852 31 04/2014 00 0 548,352 2 03/2014 00 0 142,679 :4 02/2014 06 0 . 01/2014 06 0 . 12/2013 06 0 - 11/2013 00 0 13,269 10/2013 00 0 100,689 :4 09/2013 00 0 238,802 2 08/2013 00 0 138,012 2 07/2013 00 0 197,045 2 06/2013 00 0 373,177 2 05/2013 00 0 546,257 3 04/2013 00 0 107,530 1: 03/2013 06 0 0 1 02/2013 00 0 9,915 4 01/2013 00 0 19,829 - a . 4 - - 12/2012 00 0 64,831 1 . 11/2012 00 0 69,181 2 10/2012 00 0 160,749 1: 09/2012 06 0 0 a 08/2012 00 0 85,966 :4 07/2012 00 0 187,909 1 - 06/2012 00 0 417,840 2 05/2012 06 . 04/2012 06 0 . 03/2012 00 0 02/2012 00 0 0112012 06 0 . ?11- 12/2011 06 0 . 11/2011 county: I Opr @1150: 9am I "911*: Section: Twn: Rng: BM: ELM4:37:20 Well Info 55 ?ask Eudustinn Data Emdus?nn staph API: 03721872 open [Southern Calif. Gas Co. Field; Canyon I I lFernando Fee Area: [Any Area pool; I Sesnon?Frew 02/2015 District: ?30 .1 well Type: Wall Status: [Active J. 7' . 3'5" In?. . 09/201 00 0 276,812 08/2015 00 0 117,025 07/2015 06 0 0 06/2015 00 0 123,542 05/2015 00 0 355,916 04/2015 00 0 472,441 03/2015 0 232,552 0 0 01/2015 12/2014 11/2014 10/2014 09/2014 08/2014 07/2014 06/2014 00 05/2014 00 04/2014 00 03/2014 00 02/ 2014 06 11/2013 00 10/2013 00 09/2013 06 08/2013 06 07/2013 06 06/2013 06 05/2013 06 04/2013 06 03/2013 06 02/2013 00 01/2013 00 386,454 539,973 445,675 494,557 6,919 I 12/22 00 0 11/2012 00 0 80,711 10/2012 00 0 352,706 09/2012 00 0 211,950 08/2012 00 0 100,537 07/2012 90 0 219,227 06/2012 00 0 487,457 05/2012 06 0 0 04/2012 06 0 0 03/2012 00 0 66,038 02/2012 00 0 14,329 01/2012 06 0 0. I mm 12/2011 06 0 0 11/2011 00 0 49,875 1w: Injssiism Exam: ?11m: ?unk nan wand]: usmo county: @mm Ham: Section: Twn: Eng: BM: 31.1mm 1/30/2015 4:47: 10 Well Info s5 ?ask 211001111190 nan Emdus?nn Elm Data staph Hints]: API: 03721878 open ISouthern Calif. Gas CO. Field: [Aliso Canyon I 1010 I Lease: lPorter Area: I AW Area pool; I Sesnon?Frew Entry: 3/1/1929 09/2015 00 0 08/2015 00 0 07/2015 06 0 06/2015 00 0 05/2015 00 0 04/2015 00 0 03/2015 00 0 02/2015 06 0 0 _m - 01/2015 06 .-3- $142.5 2 06 11/2014 00 10/2014 00 09/ 2014 06 08/2014 06 07/2014 06 06/2014 06 05/2014 00 04/2014 00 03/ 2014 06 02/2014 06 06 06 11/2013 06 10/2013 06 09/2013 00 90,495 08/2013 00 149,382 07/2013 00 213,443 06/2013 00 404,276 0512013 00 33,167 04/2013 06 0 03/2013 06 0 02/2013 06 0 01/2013 00 20,920 - 12/2012 06 0 11/2012 06 0 0 10/2012 06 0 09/2012 06 0 08/2012 00 0 65,138 07/2012 00 0 203,566 06/2012 00 0 472,171 0512012 00 0 555,331 94/2012 00 0 424,902 03/2012 06 0 02/2012 06 0 01/2012 00 0 16,881 man 00 0 17,303 11/2011 00 0 136,074 District: nu wen me: wen status: Pool status 41" 5 .. 57,650 35,454 0 1,084 271,731 438,695 210,083 16,195 107,362 0 0 0 0 334,207 134,848 Section: Twn: Rng: BM: 131.11: I I county: @111 Well#= 000000000 1/30/2015 4:50:01 Well Info 55mm ADI: oper: [Southern Calif. Gas Co. I I84700 Jsct?gius: county: I @?gm Field: lAliso Canyon I [010 I Lease: lPorter I "911*: Area: IADY Area I I 00 I District: Section: Tun: Rug: BM: Pool: II30 I Well Type: Wall Status: ELM: 09/2015 00 237,827 08/2015 00 217,229 07/2015 00 218,203 06/2015 00 142,578 05/2015 00 305,071 04/2015 00 404,949 235,841 03/2015 00 02/2015 08 01/2015 08 - 12/2014 08 0 0 1 1/2014 00 14,950 3 2709 10/2014 00 322,948 27 2628 09/2014 00 411,248 25 2551 08/2014 00 473,486 26 2393 07/2014 00 346,862 30 2289 06/2014 00 462,834 30 2053 05/2014 00 502,872 31 1868 619,263 29 1449 144,343 18 04/2014 00 03/2014 00 02/2014 08 01/2014 nas?zaza mm 12/ 2013 00 0 0 1 1/2013 00 0 13,888 0 10/2013 00 0 101,863 0 09/2013 00 0 113,632 0 023/2013 00 0 138,015 0 07/2013 00 0 197,011 0 06/2013 00 0 373,177 0 05/2013 00 0 546,257 0 04/2013 00 0 228,931 0 03/2013 00 0 38,352 0 02/2013 00 0 84,056 0 01/2013 08 0 0 0 12/2012 00 0 50,601 0 11/2012 00 0 70,347 0 10/2012 00 0 160,749 0 09/2012 08 0 0 08/ 2012 00 0 72,289 0 07/2012 00 0 187,909 0 06/2012 00 0 444,318 0 05/2012 00 0 523,229 0 (14/2012 00 0 461,507 0 00 0 233,968 0 02/2012 00 0 50,768 0 01/201'2 00 0 59,035 0 12/201 1 00 0 75,766 ,7 0 11/2011 00 0 122,655 23 0 [1 1/ 3 0/2015 4:55 :26 Well Info BMW I E.I API: apex: [Southern Calif. Gas Co. lsgiua: county: @?gm Field: lAliso Canyon I '010 I Lease: lPorter I ?911*: Han Area: [Any Area I I00 I District: Section: Twn: Rng: BM: Pool: ?so I well Type: Wall Status: Motive 1 am: Entrw P001 Stem? 1.1.1; -, 2 - . 09/2015 00 0 277,464 0 0 08/2015 00 0 107,766 10 2632 0 07/2015 00 0 247,543 24 2604 0 0 05/2015 00 0 164,318 22 2592 0 0 05/2015 00 0 355,916 30 2590 0 0 04/2015 00 0 472,441 30 2367 0 0 03/2015 00 0 233,641 21 2132 0 02/2015 11/2014 06 0 0 0 0 10/2014 06 0 0 0 0 09/2014 06 0 0 0 0 08/2014 05 0 0 0 0 07/2014 06 0 0 0 0 06/2014 06 0 0 0 0 05/2014 00 0 1781 0 0 04/2014 00 0 1462 0 0 03/2014 00 0 0 0 02/2014 06 0 0 0 01/2014 06 0 0 0 12/2013 00 0 12,69 8 0 0 11/2013 00 0 17,102 8 0 0 10/2013 00 0 109,726 18 0 0 09/2013 00 0 52,175 6 0 0 08/2013 00 0 161,017 20 0 0 07/2013 00 0 229,901 26 0 0 06/2013 00 0 435,374 27 0 0 05/2013 00 0 637,300 31 0 0 04/2013 00 0 165,552 13 0 0 03/2013 00 0 457 1 0 0 02/2013 06 0 0 0 01/2013 06 ,0 0 0 mull-m 12/2012 06 0 0 0 11/2012 00 0 82,072 24 0 0 10/2012 00 0 422,639 29 0 0 09/2012 00 0 197,060 20 0 08/2012 00 0 107,507 11 0 0 07/2012 00 0 108,069 9 0 0 06/2012 06 0 0 0 0 0 05/2012 06 0 0 0 0 0 04/2012 06 0 0 0 0 0 0372012 00 0 45,241 4 0 ?0 02/2012 00 0 9,817 4 0 0 01/2012 00 0 50.134 9 0 0 12/2011 06 0 0 0 0 1112011 00 0 146,866 23 4:56:30 Well Info SS Emduslinn Emdustinn Wanam? API: oper: ISouthern Calif. Gas Co. Isgius: county: @m MIL Field: IAliso Canyon I I010 I Lease: IPorter I "911*: HID. . Area: [Any Area I I 00 I District: Sect-.1011: Twn: Rug: BM: Pool: [Sesnon-Frew I I30 I Well Type: Wall Status: 31M: mmtifx' 7 1. 2.011.?; .- .. 55:; 09/2015 00 0 218,008 26 2714 0 0 08/2015 00 0 84,684 10 2632 0 0 07/2015 00 0 194,485 24 2610 0 06/2015 00 0 129,100 22 2605 0 0 05/2015 00 0 279,648 30 2578 0 0 04/2015 00 0 371,204 30 2386 0 03/2015 00 0 183,575 21 2138 0 0 02/2015 11/2014 10/2014 09/2014 06 0 0 0 0 08/2014 07/2014 06/2014 05/2014 00 0 420,767 28 1791 0 0 04/2014 00 0 539,390 27 1435 0 0 03/2014 00 0 122,171 18 0 02/2014 11/2013 00 0 8 0 0 10/2013 00 0 18 0 09/2013 00 0 5 0 0 08/2013 06 0 0 0 0 07/2013 06 0 0 0 0 06/2013 06 0 0 0 0 05/2013 06 0 0 0 0 04/2013 06 0 0 0 0 03/2013 06 0 0 0 0 02/2013 06 0 0 0 0 01/2013 silhurz 12/2012 06 0 0 0 11/2012 06 0 0 0 0 10/2012 06 0 09/2012 00 0 12 0 0 08/2012 00 0 11 0 07/2012 00 0 9 0 0 06/2012 06 0 0 0 0 05/2012 06 0 04/2012 06 0 0 0 0 03/2012 00 0 4 0 7 0 02/2012 00 0 4 0 01/2012 00 0 9 0 0 m- 12/2011 06 0 0 0 0 11/2011 00 0 115,395 23 0 1 [1 1/30/2015 7:27:20 Well Info Bank Data ?18911 ?13011 Data Banal! m: open usmo 1332:?: county: @412 mm Field: [Aliso Canyon '010 I Lease: lFernando Fee ?911*: HID. Area: I Any Area H00 Pool: I Sesnon?Frew 4/1/1976 . 08/2015 07/2015 06/2015 05/2015 04/2015 03/2015 02/2015 01/2015 ?114.- 12/2014 1 1/2014 10/2014 09/2014 08/2014 07/2014 06/2014 05/2014 04/2014 03/2014 02/2014 2014 01/ 1 1/013 I 11/2013 10/2013 09/2013 08/2013 07/2013 06/2013 05/2013 04/2013 03/2013 02/2013 01/2013 00 12/2012 00 11/2012 00 10/2012 00 09/2012 06 08/2012 06 07/2012 06 06/2012 06 0512012 06 04/2012 06 0312012 00 02/2012 00 01/2012 06 - . 12/2011 0 11/2011 00 Pool Status 000000000000 c>c>crc313 District: [30 I Wen Type: Wall Status: - 21560 7 217,199 218,290 140,716 305,071 404,949 199,330 74,058 202,154 323,555 502,349 331,337 462,834 502,836 567,269 119,531 0 0 :mmggi 772 84,353 238,802 138,015 196,951 373,177 546,257 229,020 34,518 0 15,65 4 72,609 216,448 Section: Twn: Rng: BM: 19 2656 24 2622 22 2606 30 2615 30 2402 20 2171 17 2160 8 2265 3 2631 5 2740 18 2696 23 2603 28 2526 29 2263 30 2110 31 1900 27 1469 ELM: 1 :52 -. 000000000 1/30/2015 4:46:26 ATTACHMENT 6 4. Each PAL must contain a list of all the wells (injectors, producers, idle and plugged wells etc.) associated with the project. 5. Every project formation fracture gradient must be based on a SRT conducted on the project’s injection zone(s). Also, the date of the test must be specified on the PAL. A PAL for multiple injection zones, must identify the fracture gradient for each zone. B. Area of Review Evaluations As of December 2013, there were 268 injection projects listed in District 1, of which 154 were active projects. A review of a sample of District 1 injection projects was conducted to confirm whether appropriate and complete AORs had been submitted by the operator and reviewed by the Division. The MC Unit Review Team selected 45 injection projects for evaluation. UIC project files and well files were reviewed to gather data for this evaluation. This sample group comprised various project statuses (40 active, 4 terminated, and 1 rescinded project), from fields discovered in the 1930s and 1940s. The selected projects included a variety of project approval dates and project types, including water flood (WF), water disposal (WD), and gas storage (GS). Of the 45 projects used as a sample population for this review of AOR use, 24 projects were permitted pre-Primacy (pre-March 1983), and 21 projects were permitted post-Primacy. Of the 24 pre-Primacy projects, 20 projects were permitted before, and four after, the 1978 regulations (CCR Title 14, section 1724, February 17, 1978). Of the 21 post-Primacy projects, 16 projects were permitted before, and five after, the 2010 UIC Letter of Expectations. Tables 2 and 3 respectively, present the pre- and post-Primacy injection project findings summaries for the sample group reviewed. Tabulated data includes: project status, initial project approval date, whether an AOR was completed, number of “bad” wells identified, and comments regarding how identified potential zonal conduits were addressed. An overview of the criteria required for evaluation of the appropriateness and completeness of an AOR is presented within Appendix B of this report. As detailed in the appendix, the presence, or lack of supporting AOR-essential criteria within a project or well file was used to determine whether the required project review could have been completed. For example, it is highly unlikely that an AOR could have been completed without casing diagrams. Casing diagrams submitted with injection project applications are critical in determining zonal isolation within the AOR. Casing diagrams are therefore a crucial application component that, when missing, suggests that an AOR could not have been conducted. When an AOR is delineated, the casing diagrams of the wells (including open-hole wellbores) within the AOR are closely evaluated as potential conduits for fluid migration outside the intended zone of injection. For the purposes of this review, wells evaluated are classified as Appendix 1: UIC Program Assessment Report, District 1 Page 11 “good,” “bad,” or “gray.” Wells are classified as “good” when they meet current standards of zonal isolation. Those wells identified as direct or partial conduits due to poor, inadequate or lack of cement, or mechanical problems, are classified as “bad” wells subject to remediation prior to commencement of any injection. A third category of wells referred to as “gray” wells do not fit into either of the first two categories. Gray wells were either completed and/or abandoned to the standard existing at the time of their drilling, but are not now cemented to the current standard as required by CCR section 1722.4 (Cementing casing); or do not meet the specific plugging and abandonment or annular cement lengths required by CCR, Chapter 4, Article 3, Sections 1723.1 (a) (Plugging of Oil or Gas Zones) and 1723.2 (Plugging for Freshwater Protection), Section 1723.1(b); 1723.1 (c) (4) (open hole plugging and abandonment). Determinations Tables 2 and 3 present findings summaries of the 45 projects evaluated. Figures 1 through 4, present illustrated analyses of the AOR evaluation findings discussed below. District 1 - Pre-Primacy Projects Review Only 1 of the 24 approved pre-Primacy injection project files evaluated contained sufficient AOR-essential criteria to support a complete AOR. Although these projects were approved (including the 2 terminated and 1 rescinded projects-see Table 2) pre-Primacy, all of the projects remained active post-Primacy and in conformance with Primacy requirements, should have been reviewed, updated, and issued a modified PAL. Figure 1 on the following page provides an illustration of the number and percentages of AORs, completed (blue) and not completed (red) for projects sampled from the pre-Primacy and postPrimacy time periods. Common deficiencies in pre-Primacy AOR project file evaluations include: missing well lists, missing well casing diagrams, casing diagrams with insufficient data such as the location of the top of the injection zone(s) (TIZ), cement information, specific USDW depths, or reference to a USDW, and well histories with inconsistent information. Appendix 1: UIC Program Assessment Report, District 1 Page 12 Figure 1: Appropriate AOR’s completed Pre- and Post-Primacy (total 45 selected projects). AOR’s not completed (78%) are shaded red and AOR’s completed (22%) are shaded blue. All but one of the completed AORs was completed during the post-Primacy period. District 1 – Post-Primacy Projects Review A representative sample of 21 approved post-Primacy projects were reviewed for the presence of appropriately delineated and complete AOR evaluations, and to determine if potential conduits for injection fluid were present. Nine of the 21 projects were appropriately delineated and had complete AOR evaluations; 12 projects did not. A total of 154 bad wells were identified by District 1 post-Primacy AOR evaluations. These results are presented in Table 3, which gives a project code number (PC no.) for each project evaluated. Highlights of the Table 3 results were as follows: 1. Two approved injection project reviews indicated that no bad wells were identified by District AOR evaluations. (PC nos. 78206011 and 84903013.) 2. Two AOR evaluations identified a significant number of bad wells still under additional review by the Division as of December 2014. (PC nos. 32400015 and 32400016.) 3. Two AOR evaluations identified bad wells that were remediated as a condition of a letter or PAL. (PC nos. 84939009 and 32018003.) 4. Three AOR evaluations identified bad wells to be addressed by implementing a monitoring program. (PC nos. 66600007, 84918008 and 47806002.) 5. Graphical data for two of the projects with monitoring programs was not submitted to the UIC Program Assessment Report, District 1 13 P a g e Division in accordance with a stated condition of the PAL. (PC nos. 66600007 and 47806002.) 6. Applicant operator submitted incomplete AOR data to the Division. In one instance, out of 57 wells in the one-quarter mile AOR, only 7 casing diagrams were submitted for review. A review of the casing diagrams shows inadequate casing information; moreover, there was no information on the diagrams locating the top of injection zone. (PC no. 66600008.) 7. For the 12 post-Primacy projects identified in this review as having incomplete AOR evaluations, the data suggest that the District did not identify or address them. For each of these 12 projects, AORs should have been completed during the initial project application evaluation before the issuance of a PAL especially considering these projects were permitted under the post-Primacy agreement. Annually thereafter, these projects could have been brought up to standard during the APR but were not. 8. Nine of the 21 project applications approved post-Primacy had appropriate AOR evaluations completed. Eight of the nine applications were approved between 2005 2013. This demonstrates an improvement in AOR completions for new applications. 9. Many project files failed to contain maps of the directional path of the wells within the AOR completely, or at all. Prior to 2010, AORs did not include the directional path of wells in the area surrounding the proposed injection wells to determine the AOR boundary. Consequently, a complete or accurate list of wells within the AOR was not available. 10. Records were frequently insufficient to determine if problem wells found in the AOR evaluation were remediated prior to commencing injection. Other Determinations Concerning Post-Primacy Projects: 11. Following direction from upper Division management in 2012, District 1 no longer required use of the term “remediation” in permit language regarding “bad” wells (potential injection fluid conduits) identified during AOR evaluations. The approved PAL terminology was changed from “remediate” to “address.” It is unclear whether this terminology change was intended to mean remediation, or merely monitoring. From 2009 to 2012 there was an increase in the number of applications for new or extension of existing injection projects. This surge of applications, together with the number of incomplete applications in the queue awaiting required data, resulted in delays of project approvals. In 2012, to expedite the injection project evaluation and approval process, a new Division policy was established that allowed operators to add injection wells (new wells or well conversions) within existing injection project boundaries, without comprehensive AOR reviews. This “deferral” policy was initiated based on the premise that AOR evaluations would be performed later, during the APR process, and that the subject fields had previously been through the AOR evaluation process. UIC Program Assessment Report, District 1 14 P a g e 12. A review of 159 projects for APR compliance found that 5 projects had APR within the last 5 years, 135 had no evidence of an APR conducted within the last 5 years (some as long as 20 years), and 19 had no APR conducted. Evidence suggests reliance on a questionnaire submitted by operators was used as an APR. For a more in-depth analysis, refer to Table 10, in the annual project review section of this report. Figures 2 and 3 below illustrate the results of the reviewed injection project evaluations and breakdown of well status percentages within the 10 completed injection projects identified both prePrimacy (1 project) and post-Primacy (9 projects). Overview of Pre-Primacy and Post-Primacy Injection Projects Evaluated for AOR Completion 78% 22% Breakdown of Wells Reviewed Bad Wells 155 (8%) Gray Wells 176 (9%) 1,671 (83%) Good Wells 200 COMPLETED AOR'S - 10 AOR'S NOT COMPLETED - 35 600 1000 1400 1800 # Of Wells Note: A total of 2,002 wells from 10 AORs were evaluated Figure 2: Overview of Pre-Primacy and Post-Primacy Injection Projects Evaluated for AOR Completion. An AOR evaluation should have been completed for each of the 45 selected projects. Figure 3: Breakdown of Wells Reviewed (from the 10 completed AORs) showing the numbers and sample population percentages of the good, gray, and bad wells identified from the District 1 review of the 10 completed AORs. Seven In-Depth AOR Evaluations Conducted During This Review: Based on the finding that 35 out of the 45 pre- and post-Primacy projects reviewed had no AOR evaluations, the MC Unit selected a subset of 7 project files from this group to perform its own in-depth AOR evaluations. The MC Unit Review Team identified and listed the wells in each AOR, reviewing individual well histories and evaluating casing diagrams. Determinations These focused evaluations led to the following determinations: 1. A total of 230 well casing diagrams from the 7 injection projects were reviewed for zonal isolation. The review indicated that 37 wells (16%) were “bad”, 69 wells UIC Program Assessment Report, District 1 15 P a g e ATTACHMENT 7 Well Info API: oper: ISouthern Calif. Gas Co. laggiusi county: Field: ?liso Canyon '010 i Lease: I Fernando Fee I "9114}: HEP. Area: IADY Area I I00 I District: Section: Twn: Rng: BM: Pool: porter?Del Aliso ?15 I Well Type: Wall Status: ELM: 09/2015 00 59,813 30 0 1 1 08/2015 00 77,055 31 0 1 1 07/2015 00 80,416 31 1500 1 1 06/2015 00 68,896 30 0 1 1 05/2015 00 71,334 31 0 1 1 04/2015 00 64,686 30 1 1 03/2015 00 74,879 31 0 0 0 02/2015 00 56,980 28 0 0 0 01/2015 00 77,276 31 0 0 0 . sizsm-t-J 5::9?3712149 T- 12/2014 00 83,916 0 11/2014 00 65,072 29 910 10/2014 00 72,690 31 0 09/2014 00 74,795 30 0 08/2014 00 81,589 31 0 07/2014 00 84,423 31 0 06/2014 00 78,846 30 0 05/2014 00 113,799 31 0 04/2014 00 61,552 28 0 03/ 2014 00 92,810 02/2014 00 81,372 01/2014 00 54,085 . z" 3"}3 75; 12/2013 00 54,369 0 11/2013 00 57,789 0 10/2013 00 52,787 0 09/2013 00 55,453 0 08/2013 00 57,733 0 07/2013 00 56,540 0 06/2013 00 44,706 0 05/2013 00 1,553 0 04/2013 00 1,312 0 03/2013 00 766 0 02/2013 00 41 0 01/2013 00 1,253 0 - 12/2012 00 1,381 0 11/2012 00 1,403 0 10/2012 00 7,170 0 09/2012 06 0 0 0 08/2012 06 0 0 0 07/2012 06 0 0 0 06/2012 00 4 0 1 05/2012 06 0 0 0 04/2012 00 30,306 0 25 7 "073/2012, 5777700) 45,541 '0 ?29 02/2012 00 38,547 0 29 2 01/2012 00 26,482 0 23 _l 1212.011 06 0 0 0 11/2011 00 16,947 0 20 8:58:45 Well Info API: oper: lSouthern Calif. Gas Co. ?84700 lsgius. County: @119?: Field: lAliso Canyon I [010 Lease; IPorter I ?911*: Hill Area: [My Area I I00 I District: Section: Twn: Rng: EM: Pool: Porter?De1 Miso 4115 Wall Type: Wall Status: ELM: Entry: Pool Status: Active I 1 - . . 09/2015 1,252 0 0 1 1 08/2015 2,169 0 0 1 1 07/2015 1,209 0 1200 1 1 06/2015 2,170 0 0 1 1 05/2015 1,974 0 0 1 1 04/2015 1,259 0 0 1 1 03/2015 1,473 0 0 1 1 02/2015 649 0 0 1 1 01/2015 1,051 0 0 1 1 9311.11.19, 12/2014 00 2,506 0 0 1 1 11/2014 00 1,439 0 1100 1 1 10/2014 00 1,332 0 0 1 1 09/2014 00 1,543 0 0 1 1 08/2014 00 2,478 0 0 1 1 07/2014 00 2,510 0 0 1 1 06/2014 00 2,191 0 0 1 1 05/2014 00 5,988 0 0 1 1 04/2014 00 3,810 0 0 1 1 03/2014 00 2,625 0 1 1 02/2014 00 1,282 0 1 1 01/2014 00 1,243 2/201 00 1,890 0 1 1 11/2013 00 3,018 0 1 1 10/2013 00 2,297 0 1 1 09/2013 00 2,637 0 1 1 08/2013 00 1,267 0 1 1 07/2013 00 4,473 0 1 1 06/2013 00 6,622 0 1 1 0512013 00 4,077 0 1 1 04/2013 00 2,257 0 1 1 03/2013 00 962 0 1 1 02/2013 08 0 0 1 1 01/2013 3:5: 12/2012 00 818 0 22 1 1 11/2012 00 1,581 0 30 1 1 10/2012 00 1,221 0 28 1 1 09/2012 00 1,685 0 29 1 1 08/2012 00 994 0 31 1 1 07/2012 00 1,822 0 31 1 1 06/2012 00 1,173 0 29 1 1 05/2012 00 838 0 31 1 1 04/2012 00 1,864 0 29 1 1 740-37701? 452 29 1 7 1 ,02/2012 00 1,875 0 29 1 1 01/2012 12/201 00 1,076 0 23 1 1 11/2011 00 1,853 0 3D 1 1 1/30/2015 9:28:48 Well Info ?ag; I . I I API: Oper: F?'llh?ru halif. ?10. I [34700 Isgius: County: Angeles ?93m Field: IAliso canyon ?010 I Lease: lPorter I Well#: __24 Han. Area: IAny Area I [00 I District: SectiOn: Tm: mg: m: POOL [Porter'DEl Aliso ?15 I Well Type: Well Status: ??Active Em: I: gift-d . .. 09/2015 08/2015 00 1,706 0 3 0 1 1 07/2015 00 1,180 0 8 1000 1 1 06/2015 00 15,372 0 20 0 1 1 05/2015 00 20,955 0 31 0 1 1 04/2015 00 21,988 0 30 0 1 1 03/2015 00 26,652 0 31 0 1 1 02/2015 00 12,987 0 28 0 1 1 01/2015 00 24,171 0 31 0 1 1 12/2014 00 0 1 11/2014 00 0 1 10/2014 00 0 1 09/2014 00 0 1 08/2014 00 0 1 07/2014 00 0 1 06/2014 00 0 1 05/2014 00 0 1 04/2014 00 0 1 03/2014 00 0 1 02/2014 00 0 1 01/2014 00 0 1 12/2013 00 33,830 0 30 1 1 11/2013 00 39,632 0 30 1 1 10/2013 00 34,868 0 27 1 1 09/2013 00 34,380 0 30 1 1 08/2013 00 32,728 0 31 1 1 07/2013 00 12,901 0 11 1 1 06/2013 00 1 0 1 1 1 05/2013 00 14,307 0 16 1 1 04/2013 00 25,023 0 30 1 1 03/2013 00 18,838 0 30 1 1 02/2013 00 487 0 27 1 1 01/2013 00 32,100 0 31 1 1 2/2012 00 33,684 0 31 1 1 11/2012 00 31,744 0 30 1 1 10/2012 00 25,971 0 28 1 1 09/2012 00 29,892 0 30 1 1 08/2012 00 19,096 0 31 1 1 07/2012 00 35,174 0 31 1 1 06/2012 00 25,053 0 29 1 1 05/2012 00 28,280 0 31 1 1 04/2012 00 28,359 0 30 1 1 703/2012 7 ?15,278 0 1 1 02/2012 00 32,194 0 28 1 1 ?0112012 00 31,033 a 29 1 1 12/2011 00 33,271 0 29 1 1 11/2011 00 27,802 29 1 1 1/30/2015 9:29: 10 Well Info API: open lSouthern Calif. Gas Co. ?54700 Jsgius: County: @511? Field: [Aliso Canyon Lease; lPorter I Well#: Area: IAIW Area I r00 District: Section: Twn: Rng: BM: Pool: Aliso Well Type: Well Status: 31.14: I: lr l: . 09/2015 00 08/2015 00 07/2015 00 06/2015 00 05/2015 06 04/2015 06 03/2015 06 02/2015 06 01/2015 06 ?(j-Uni 1:10:2? 1 /2014 00 0 11/2014 06 0 10/2014 06 0 09/2014 06 0 08/2014 06 0 07/2014 00 0 06/2014 00 0 05/2014 00 0 04/2014 00 0 03/2014 00 0212014 00 0112014 00 12/2013 00 11/2013 00 10/2013 00 09/ 2013 00 08/2013 00 07/2013 00 06] 2013 00 05/ 2013 00 04/ 2013 00 03/2013 00 02/2013 00 01/2013 00 12/2012 00 11/2012 00 10/2012 00 09/2012 00 08/2012 00 07/2012 00 06/2012 00 05/2012 00 A 114/2012 0 03/2012 06 02/2012 06 01/2012 06 12/2011 06 11/2011 06 1/3 0/2015 9:29:29 Well Info IWIWI lop-er; lSouthern Calif. Gas Co. H?s-nun [82:118- c?mty: @m lhliso Canyon I 010 I Lease; I Putter ?@110: ma: In?? I In? I District: Section: Tun: Eng: 311: P001: Inlzso IN: Wall Type: Wall Status: Waive 3111: spay: pool status: [Acme a 13:! c. 912015 0 0 1 1 0312015 0 1 0 -1 1 07/2015 0 i 0 1 1 06/2015 0 2 0 1 1 05/2015 0 31 0 1 1 0412015 0 3 0 1 1 0312015 0 31 0 1 1 02/2015 0 2 0 1 1 01112015 0 21 0 1 1 12/2014 00 0 1 0 1 1 1112014 00 0 2 1050 1 1 10112014 00 0 31 0 1 1 09/2014 00 0 3 0 1 1 0812014 00 0 31 0 1 1 0712014 00 0 31 0 1 1 06/2014 00 0 1 1500 1 1 0512014 00 0 150.0 1 1 0412014 00 0 2 0 1 1 03/2014 00 0 31 1 1 0212014 00 0 2. 1 1 01/2014 00 0 I 1 1 m? 1212013 00 0 2 1 1 1112013 00 0 2 1 1 1012013 00 0 2' 1 1 0912013 00 0 3' 1 1 0012013 00 0 3 1 1 0712013 00 0 3 1 1 0612013 00. 0 1 1 1 05/2013 00 0 0 I 1 1 0412013 06 .0 .0 1 1 031-2013 05 0 0 i 1 1 0212013 06 0 0. 1 1 011.2013. 05. 0 1 1 1212012 05 .0 0 1 1 11.12012 00 12,325 0 2 1 1 10/2012 00 12,575 0 2 1 1 09120.12 00 1.3.3.07 0- 3 1 1 0812012 00 9,320 0 3 1 1 07!2012 .00 12.16.? 0 3 1 1 0612012 00 71.273 0 3 I 1 1 05/2012 00 10,380 0 3 1 1 04120.13 '90. 5.511 I 1 1 03132012 00 5 13' 1 1 02,12012 06 '0 0 I 1 1 0112012 1222011 '05 0 0 I 1 1 1112011 05 a [1 1/30/2015 9:30: 1 8 Well Info API: Oper: [Southern Calif. Gas Co. I '54700 county: L03 Angeles QM Field: [Aliso Canyon I I010 I Lease: IFernando Fee I well? 36 Area: [Any Area I I00 I District: Section: Twn: Eng; 34: 9001: Porter?D631 mm ?6 I [15 I ?911 Type: Wall status: ??Active ELM: El Entry: Pool Status: 09/2015 0 1 1 08/2015 0 1 1 07/2015 0 1 1 06/2015 0 1 1 05/2015 0 1 1 04/2015 0 1 1 03/2015 0 0 0 02/2015 0 0 0 01/2015 0 0 0 12/2014 0 26 0 0 0 11/2014 0 29 860 0 0 10/2014 0 31 0 0 0 09/2014 0 30 0 0 0 08/2014 0 30 0 0 0 07/2014 0 28 0 0 0 06/2014 0 26 0 0 0 05/2014 0 2 0 0 0 04/2014 0 0 0 0 0 03/2014 0 1 0 0 02/2014 0 20 0 0 01/2014 00 25,237 0 27 0 0 I .111; 4W 1- - - . 12/2013 00 0 30 0 0 11/2013 00 0 30 0 0 10/2013 00 0 27 0 09/2013 00 0 30 0 08/2013 00 0 31 0 07/2013 00 0 31 0 06/2013 00 0 29 0 05/2013 00 0 29 0 04/2013 00 0 29 0 0 03/2013 00 0 30 0 0 02/2013 00 0 28 0 0 01/2013 00 0 31 0 . I-.. t! with 12/2012 00 21,916 0 31 0 0 11/2012 00 23,397 0 30 0 0 10/2012 00 28,692 0 30 0 0 09/2012 00 43,307 0 30 0 08/2012 00 27,522 0 31 1 1 07/2012 00 56,385 0 31 1 1 06/2012 00 38,267 0 29 1 1 05/2012 00 3,883 0 9 0 0 04/2012 00 23,718 0 30 ?03/2012 00 25,685 -0 28 *0 0 02/2012 00 17,863 0 28 0 0 011/201 00 20,278 0 29 -. 12/2011 00 31,785 0 28 0 0 11/2011 00 24,499 0 30 10&UsrP?RecemYearFirst: [1 ?30/20 15 9 28:23 ATTACHMENT 8 DISTRICT-LEVEL DISCUSSIONS AND CONCLUSIONS - DISTRICT 6 or subzone, at least one geologic cross section through at least one injection well in the project area, e-logs, characteristics of the cap rock. If the adequacy of the confining system is in question, what options are considered to compensate for this uncertainty and how are they evaluated? The Associate O&G Engineer reviews the project, looking at all the wells in the AOR– and all the submitted data, and if there is uncertainty, the Associate will contact the operator to discuss and to obtain possibly more information which may consist of further testing or remedial work by the operator. It is important to note that if uncertainty remains, we would not approve the project. Describe the monitoring system requirements for flow rate, cumulative volumes, tubing pressure, annulus pressure, etc. for a Class II injection well. DOGGR receives production/injection information on a monthly basis from the operator. On an annual basis, each well is visited to perform an environmental inspection to evaluate environmental compliance and pressure monitoring purposes. At that time the pressures are taken from the gauges at the wellhead and compared to the approved MASP. Also, during the MIT testing; flow, pressure and facilities are checked. All the observed data is compared to reported data to ensure operator is complying with project approval, P reports and other requirements. Does this monitoring and reporting include observation or measurement of annulus pressures? The operator is not required to report annulus pressures unless a MI failure is evident from monitoring annulus pressure during operations. The well must be shut in pending repairs if that is the case. DOGGR inspects the annulus pressure during annual MIT surveys. The casing valve is open during RAT surveys, which will reveal excessive pressure on the annulus. How are the maximum injection pressures and rates established? Please provide examples of step rate tests conducted and other data used for this purpose. Due to known stratigraphy and subsurface condition in District 6, a standard 0.8 psi/foot gradient is used to calculate MASP. We use a gradient of 0.465 for salt water – subtract from 0.8 and multiply by the depth of the top perforation. We don‟t consider friction loss in our determination. Step rate tests are required if the operator wants to possibly inject at a higher pressure than the MASP and need to prove to DOGGR that they will not be going over fracture gradient. When a step rate test is performed the operator starts from hydrostatic to the pressure required to fracture the injection zone or the proposed injection pressure, whichever occurs first. Please elaborate on how the standard 0.8 gradient was established for wells throughout District 6. Is it based on step-rate tests or other pressure data, or on other calculations? The 0.8 psi/foot gradient has been a statewide/central valley standard. In my experience with the Bakersfield District (1975-2003), step rate tests conducted for water disposal projects were in line with the 0.8 psi/foot gradient. We have had one new water disposal project approved during my one-year tenure with this district. The step rate test conducted for this project determined a fracture gradient of 0.6 psi/foot. The project is completed into the Hamilton & McCormick zones, in Maine Prairie gas field, with perforated intervals between 5,300‟-5,700‟. The operator should have no difficulty injecting anticipated water volumes at the MASP based upon 0.6 psi/foot. California Class II UIC Program Review June 2011 202 James D. Walker Horsley Witten Group, Inc. ATTACHMENT 9 Aliso Canyon Natural Gas Leak Preliminary Estimate of Greenhouse Gas Emissions to Date (As of November 20, 2015) On October 23, Southern California Gas informed the State of a natural gas leak at its Aliso Canyon natural gas storage facility. This document provides a preliminary estimate of the amount of methane released since then through today, November 20. Natural Gas is composed primarily of methane (approximately 80%), which is a potent greenhouse gas. Methane is in a category of greenhouse gases known as short-lived climate pollutants. These types of gases remain in the atmosphere for a much shorter period of time than longer-lived climate pollutants, such as carbon dioxide (CO2); but when measured in terms of how they heat the atmosphere, their impacts can be tens, hundreds, or even thousands of times greater than that of carbon dioxide The global warming impact from methane is 25 times and 72 times that of CO2, for equal amounts by weight, over a 100 year and 20 year timespan, respectively. Due to methane’s powerful impact and short life compared to other gases it represents an important element in reducing the near-term effects of global warming. In order to quantify the methane release rate from the Aliso Canyon gas leak, state agencies in collaboration with the research community are collecting measurements near the ground at the well site, and from towers, airplanes and satellites. These varied measurements can be used to calculate an instantaneous emission rate, which in turn will assist with estimating the total methane emissions associated with the leak. One such type of measurement was made by Scientific Aviation on November 7 and 10 using a small airplane capable of measuring methane and ethane. Ethane uniquely identifies methane from a fossil fuel source and enables separating the methane plume from the Aliso Canyon from that of a nearby landfill. By flying through the downwind methane plume at several elevations, a methane flux can be calculated. 1 Data captured on November 7 and 10 from these airplane readings indicates an emission rate during these periods of approximately 44,000±5,000 kilograms of methane per hour and 50,000±16,000 kilograms of methane per hour, respectively. If the release of methane has been constant at these estimated rates since October 23 and through today November 20th, the Aliso Canyon gas leak would have generated about 0.80 million metric tons of carbon dioxide equivalent (MMTCO2e) to date. This figure uses a 100-year global warming potential of 25 for methane in order to equate the methane impact with carbon dioxide over a hundred-year period. To put the preliminary estimate into context, Figure 2 shows the preliminary estimate of the gas leak’s methane release next to the total estimated methane emissions across California during the same time, from October 23rd through November 20th, by scaling to 28 days the state’s existing inventories of methane release. It suggests that the Aliso Canyon gas leak would have added approximately one-quarter to the regular statewide methane emissions from October 23 to November 20. The relative magnitude of emissions from the leak compared to other sources of methane in the State underscores the urgency of stopping the gas leak. This comes on top of problems caused by odor and any potential impacts from exposure. 2 rd Figure 2. Methane emissions in California since the detection of the Aliso Canyon leak, October 23 through th November 20 2015. Major assumptions about leak rate variability have been made in the construction of this graph. It is important to note that this estimate is preliminary, based on a small number of measurements, and assumes a constant emission rate. In reality, that rate is likely variable. The emission rate of methane at the Aliso Canyon is not expected to be constant, as Southern California Gas continues to implement a range of strategies intended to stop the leak. This preliminary estimate will be refined using additional measurements from towers, satellite overflights, remote sensing and other data sources. Scientific Aviation will likely make additional flights as well to measure emissions from the facility. A complete calculation of the total methane emitted from Aliso Canyon based on a full set of data and an assessment of any changes in methane release rate over the duration of the leak will take several months to complete. This refined estimate will be based on continuous measurements of methane made at multiple stationary sites throughout the Los Angeles basin that have been in place for several years and whose measurements span the entire episode. These data will be used in conjunction with computer simulation models to make a refined estimate of the total methane emitted. The result should also be considered in the context of the recently released Short-Lived Climate Pollutant Reduction Strategy concept paper, in which the state lays out a goal to reduce emissions of methane in the state by 40% from current levels by 2030. Oil and gas production, along with natural gas distribution, is a significant source of methane emissions and regulatory efforts are under way to reduce emissions from those sectors. For more information, contact David Clegern: (916)322-8286, dclegern@arb.ca.gov 3 EXHIBIT 4. Each PAL must contain a list of all the wells (injectors, producers, idle and plugged wells etc.) associated with the project. 5. Every project formation fracture gradient must be based on a SRT conducted on the project’s injection zone(s). Also, the date of the test must be specified on the PAL. A PAL for multiple injection zones, must identify the fracture gradient for each zone. B. Area of Review Evaluations As of December 2013, there were 268 injection projects listed in District 1, of which 154 were active projects. A review of a sample of District 1 injection projects was conducted to confirm whether appropriate and complete AORs had been submitted by the operator and reviewed by the Division. The MC Unit Review Team selected 45 injection projects for evaluation. UIC project files and well files were reviewed to gather data for this evaluation. This sample group comprised various project statuses (40 active, 4 terminated, and 1 rescinded project), from fields discovered in the 1930s and 1940s. The selected projects included a variety of project approval dates and project types, including water flood (WF), water disposal (WD), and gas storage (GS). Of the 45 projects used as a sample population for this review of AOR use, 24 projects were permitted pre-Primacy (pre-March 1983), and 21 projects were permitted post-Primacy. Of the 24 pre-Primacy projects, 20 projects were permitted before, and four after, the 1978 regulations (CCR Title 14, section 1724, February 17, 1978). Of the 21 post-Primacy projects, 16 projects were permitted before, and five after, the 2010 UIC Letter of Expectations. Tables 2 and 3 respectively, present the pre- and post-Primacy injection project findings summaries for the sample group reviewed. Tabulated data includes: project status, initial project approval date, whether an AOR was completed, number of “bad” wells identified, and comments regarding how identified potential zonal conduits were addressed. An overview of the criteria required for evaluation of the appropriateness and completeness of an AOR is presented within Appendix B of this report. As detailed in the appendix, the presence, or lack of supporting AOR-essential criteria within a project or well file was used to determine whether the required project review could have been completed. For example, it is highly unlikely that an AOR could have been completed without casing diagrams. Casing diagrams submitted with injection project applications are critical in determining zonal isolation within the AOR. Casing diagrams are therefore a crucial application component that, when missing, suggests that an AOR could not have been conducted. When an AOR is delineated, the casing diagrams of the wells (including open-hole wellbores) within the AOR are closely evaluated as potential conduits for fluid migration outside the intended zone of injection. For the purposes of this review, wells evaluated are classified as Appendix 1: UIC Program Assessment Report, District 1 Page 11 “good,” “bad,” or “gray.” Wells are classified as “good” when they meet current standards of zonal isolation. Those wells identified as direct or partial conduits due to poor, inadequate or lack of cement, or mechanical problems, are classified as “bad” wells subject to remediation prior to commencement of any injection. A third category of wells referred to as “gray” wells do not fit into either of the first two categories. Gray wells were either completed and/or abandoned to the standard existing at the time of their drilling, but are not now cemented to the current standard as required by CCR section 1722.4 (Cementing casing); or do not meet the specific plugging and abandonment or annular cement lengths required by CCR, Chapter 4, Article 3, Sections 1723.1 (a) (Plugging of Oil or Gas Zones) and 1723.2 (Plugging for Freshwater Protection), Section 1723.1(b); 1723.1 (c) (4) (open hole plugging and abandonment). Determinations Tables 2 and 3 present findings summaries of the 45 projects evaluated. Figures 1 through 4, present illustrated analyses of the AOR evaluation findings discussed below. District 1 - Pre-Primacy Projects Review Only 1 of the 24 approved pre-Primacy injection project files evaluated contained sufficient AOR-essential criteria to support a complete AOR. Although these projects were approved (including the 2 terminated and 1 rescinded projects-see Table 2) pre-Primacy, all of the projects remained active post-Primacy and in conformance with Primacy requirements, should have been reviewed, updated, and issued a modified PAL. Figure 1 on the following page provides an illustration of the number and percentages of AORs, completed (blue) and not completed (red) for projects sampled from the pre-Primacy and postPrimacy time periods. Common deficiencies in pre-Primacy AOR project file evaluations include: missing well lists, missing well casing diagrams, casing diagrams with insufficient data such as the location of the top of the injection zone(s) (TIZ), cement information, specific USDW depths, or reference to a USDW, and well histories with inconsistent information. Appendix 1: UIC Program Assessment Report, District 1 Page 12 Figure 1: Appropriate AOR’s completed Pre- and Post-Primacy (total 45 selected projects). AOR’s not completed (78%) are shaded red and AOR’s completed (22%) are shaded blue. All but one of the completed AORs was completed during the post-Primacy period. District 1 – Post-Primacy Projects Review A representative sample of 21 approved post-Primacy projects were reviewed for the presence of appropriately delineated and complete AOR evaluations, and to determine if potential conduits for injection fluid were present. Nine of the 21 projects were appropriately delineated and had complete AOR evaluations; 12 projects did not. A total of 154 bad wells were identified by District 1 post-Primacy AOR evaluations. These results are presented in Table 3, which gives a project code number (PC no.) for each project evaluated. Highlights of the Table 3 results were as follows: 1. Two approved injection project reviews indicated that no bad wells were identified by District AOR evaluations. (PC nos. 78206011 and 84903013.) 2. Two AOR evaluations identified a significant number of bad wells still under additional review by the Division as of December 2014. (PC nos. 32400015 and 32400016.) 3. Two AOR evaluations identified bad wells that were remediated as a condition of a letter or PAL. (PC nos. 84939009 and 32018003.) 4. Three AOR evaluations identified bad wells to be addressed by implementing a monitoring program. (PC nos. 66600007, 84918008 and 47806002.) 5. Graphical data for two of the projects with monitoring programs was not submitted to the UIC Program Assessment Report, District 1 13 P a g e Division in accordance with a stated condition of the PAL. (PC nos. 66600007 and 47806002.) 6. Applicant operator submitted incomplete AOR data to the Division. In one instance, out of 57 wells in the one-quarter mile AOR, only 7 casing diagrams were submitted for review. A review of the casing diagrams shows inadequate casing information; moreover, there was no information on the diagrams locating the top of injection zone. (PC no. 66600008.) 7. For the 12 post-Primacy projects identified in this review as having incomplete AOR evaluations, the data suggest that the District did not identify or address them. For each of these 12 projects, AORs should have been completed during the initial project application evaluation before the issuance of a PAL especially considering these projects were permitted under the post-Primacy agreement. Annually thereafter, these projects could have been brought up to standard during the APR but were not. 8. Nine of the 21 project applications approved post-Primacy had appropriate AOR evaluations completed. Eight of the nine applications were approved between 2005 2013. This demonstrates an improvement in AOR completions for new applications. 9. Many project files failed to contain maps of the directional path of the wells within the AOR completely, or at all. Prior to 2010, AORs did not include the directional path of wells in the area surrounding the proposed injection wells to determine the AOR boundary. Consequently, a complete or accurate list of wells within the AOR was not available. 10. Records were frequently insufficient to determine if problem wells found in the AOR evaluation were remediated prior to commencing injection. Other Determinations Concerning Post-Primacy Projects: 11. Following direction from upper Division management in 2012, District 1 no longer required use of the term “remediation” in permit language regarding “bad” wells (potential injection fluid conduits) identified during AOR evaluations. The approved PAL terminology was changed from “remediate” to “address.” It is unclear whether this terminology change was intended to mean remediation, or merely monitoring. From 2009 to 2012 there was an increase in the number of applications for new or extension of existing injection projects. This surge of applications, together with the number of incomplete applications in the queue awaiting required data, resulted in delays of project approvals. In 2012, to expedite the injection project evaluation and approval process, a new Division policy was established that allowed operators to add injection wells (new wells or well conversions) within existing injection project boundaries, without comprehensive AOR reviews. This “deferral” policy was initiated based on the premise that AOR evaluations would be performed later, during the APR process, and that the subject fields had previously been through the AOR evaluation process. UIC Program Assessment Report, District 1 14 P a g e 12. A review of 159 projects for APR compliance found that 5 projects had APR within the last 5 years, 135 had no evidence of an APR conducted within the last 5 years (some as long as 20 years), and 19 had no APR conducted. Evidence suggests reliance on a questionnaire submitted by operators was used as an APR. For a more in-depth analysis, refer to Table 10, in the annual project review section of this report. Figures 2 and 3 below illustrate the results of the reviewed injection project evaluations and breakdown of well status percentages within the 10 completed injection projects identified both prePrimacy (1 project) and post-Primacy (9 projects). Overview of Pre-Primacy and Post-Primacy Injection Projects Evaluated for AOR Completion 78% 22% Breakdown of Wells Reviewed Bad Wells 155 (8%) Gray Wells 176 (9%) 1,671 (83%) Good Wells 200 COMPLETED AOR'S - 10 AOR'S NOT COMPLETED - 35 600 1000 1400 1800 # Of Wells Note: A total of 2,002 wells from 10 AORs were evaluated Figure 2: Overview of Pre-Primacy and Post-Primacy Injection Projects Evaluated for AOR Completion. An AOR evaluation should have been completed for each of the 45 selected projects. Figure 3: Breakdown of Wells Reviewed (from the 10 completed AORs) showing the numbers and sample population percentages of the good, gray, and bad wells identified from the District 1 review of the 10 completed AORs. Seven In-Depth AOR Evaluations Conducted During This Review: Based on the finding that 35 out of the 45 pre- and post-Primacy projects reviewed had no AOR evaluations, the MC Unit selected a subset of 7 project files from this group to perform its own in-depth AOR evaluations. The MC Unit Review Team identified and listed the wells in each AOR, reviewing individual well histories and evaluating casing diagrams. Determinations These focused evaluations led to the following determinations: 1. A total of 230 well casing diagrams from the 7 injection projects were reviewed for zonal isolation. The review indicated that 37 wells (16%) were “bad”, 69 wells UIC Program Assessment Report, District 1 15 P a g e