# SOUTHERN CALIFORNIA GAS CO — Notice of Amendment

**Citation:** CPF 12022052NOA  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2022-05-10

CLOSED notice of amendment citing 192.12(c).

## Document text

Notice of Amendment involving SOUTHERN CALIFORNIA GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2022-05-10 and is reported as closed as of 2022-06-28. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12022052NOA_Closure Letter_06282022_(21-231340).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022052NOA/12022052NOA_Closure%20Letter_06282022_(21-231340).pdf

12022052NOA_Closure Letter_06282022_(21-231340)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022052NOA/12022052NOA_Closure%20Letter_06282022_(21-231340)_text.pdf

12022052NOA_Notice of Amendment_05102022_(21-231340).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022052NOA/12022052NOA_Notice%20of%20Amendment_05102022_(21-231340).pdf

12022052NOA_Notice of Amendment_05102022_(21-231340)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022052NOA/12022052NOA_Notice%20of%20Amendment_05102022_(21-231340)_text.pdf

12022052NOA_Operator Response to Notice_06152022_(21-231340).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022052NOA/12022052NOA_Operator%20Response%20to%20Notice_06152022_(21-231340).pdf

12022052NOA_Notice of Amendment_05102022_(21-231340)_text.pdf

NOTICE OF AMENDMENT
OVERNIGHT EXPRESS DELIVERY
May 10, 2022
Mr. Scott Drury
President and Chief Executive Officer
Southern California Gas Co
555 West Fifth Street
Los Angeles, California 90013
CPF 1-2022-052-NOA
Dear Mr. Drury:
From October 11 through 15, 2021, an inspector from the California Geologic Energy
Management Division (CalGEM), acting as an agent for the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.)
inspected Southern California Gas Company’s (SCG) procedures for its Aliso Canyon, Honor
Rancho, and Playa Del Rey Underground Natural Gas Storage Facilities (UNGSF) located in Los
Angeles County, California and its La Goleta UNGSF located in Santa Barbara County, California.
On the basis of the inspection, PHMSA has identified an apparent inadequacy found within SCG’s
plans or procedures, as described below:
1. § 192.12 Underground natural gas storage facilities.
(a) …
(c) Procedural manuals. Each operator of a UNGSF must prepare
and follow for each facility one or more manuals of written procedures
for conducting operations, maintenance, and emergency preparedness
and response activities under paragraphs (a) and (b) of this section.
Each operator must keep records necessary to administer such
procedures and review and update these manuals at intervals not
exceeding 15 months, but at least once each calendar year. Each
operator must keep the appropriate parts of these manuals accessible
at locations where UNGSF work is being performed. Each operator



CPF 1-2022-052-NOA
must have written procedures in place before commencing
operations.
SCG’s written procedures for conducting maintenance and normal operations were inadequate to
ensure safe operation of a pipeline facility. Specifically, SCG’s Gas Standard 224.0000 Testing
and Inspection of Safety Valves and Wellhead Valves (Standard 224.0000) did not include the
actions that must be taken if manual wellhead valves required repair or replacement in accordance
with API RP 1171, Section 9.3.2 (Section 9.3.2).
Section 9.3.2 states, in part, that “[t]he valves shall be maintained, repaired, or replaced in
accordance with the operator’s valve maintenance program for isolation valves.”
During the inspection, CalGEM reviewed SCG’s Standard 224.0000, Section 6.4 (Section 6.4) and
Section 6.5 (Section 6.5). Section 6.4 stated, in part, “[i]ssue a corrective maintenance order (CM)
for any unresolved substandard conditions,” while Section 6.5 stated, in part, “[a]dditional
maintenance, repair or replacement of wellhead valves shall be planned and scheduled as needed.
”
However, no additional actions were included in the written procedures that specified how to repair
or replace manual wellhead valves.
Therefore, SCG’s written procedures were inadequate to ensure safe operation of a pipeline facility
in accordance with § 192.12(c). SCG must revise its written procedures to include the actions that
must be taken if manual wellhead valves require repair or replacement.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement
Proceedings.
Please refer to this document and note the response options. Be advised that all material you
submit in response to this enforcement action is subject to being made publicly available. If you
believe that any portion of your responsive material qualifies for confidential treatment under 5
U.S.C. § 552(b), along with the complete original document you must provide a second copy of
the document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment under
5 U.S.C. § 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice
and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice
without further notice to you and to issue an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
12022052NOA_Notice of Amendment_05102022_(21-231340)_text Page 2 of 3



CPF 1-2022-052-NOA
action will be closed.
It is requested (not mandated) that Southern California Gas Co maintain documentation of the
safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,
Eastern Region, Pipeline and Hazardous Materials Safety Administration, 840 Bear Tavern Road,
Suite 300, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF
1-2022-052-NOA and, for each document you submit, please provide a copy in electronic format
whenever possible. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should
be sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
12022052NOA_Notice of Amendment_05102022_(21-231340)_text Page 3 of 3

12022052NOA_Closure Letter_06282022_(21-231340)_text.pdf

OVERNIGHT EXPRESS DELIVERY
June 28, 2022
Mr. Scott Drury
President and Chief Executive Officer
Southern California Gas Co
555 West Fifth Street
Los Angeles, California 90013
CPF 1-2022-052-NOA
Dear Mr. Drury:
From October 11 through 15, 2021 an inspector from the California Geologic Energy Management
Division (CalGEM), acting as an agent for the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected
Southern California Gas Company’s (SCG) procedures for its Aliso Canyon, Honor Rancho, and
Playa Del Rey Underground Natural Gas Storage Facilities (UNGSF) located in Los Angeles
County, California and its La Goleta UNGSF located in Santa Barbara County, California. As a
result of the inspection, SCG was issued a Notice of Amendment on May 10, 2022, which proposed
amendment of your procedures.
SCG submitted its amended procedures on June 15, 2022. My staff reviewed the amended
procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been
corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/12022052NOA>
- Source ID: `phmsa-enforcement`
- SHA-256: `4bf95c1e41855302cb22698c7ea21006a5d064d20c985c7608225b5791be9521`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T15:33:58.798Z
- Document slug: `phmsa-enforcement-12022052noa`

### Source metadata

```json
{
  "cpf": "12022052NOA",
  "operator": "SOUTHERN CALIFORNIA GAS CO",
  "region": "Eastern",
  "pipelineType": "INTRASTATE UNDERGROUND NG STORAGE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.12(c)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 5,
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  "extractedAgencyDocumentCount": 2,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "SOUTHERN CALIFORNIA GAS CO"
}
```
