# CITY OF VERNON — Warning Letter

**Citation:** CPF 520110008W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2011-02-25

CLOSED warning letter citing 192.625(f).

## Document text

Warning Letter involving CITY OF VERNON. PHMSA's enforcement data identifies the cited regulation as 192.625(f). The case was opened on 2011-02-25 and is reported as closed as of 2011-02-25. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520110008W_warning letter_02252011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110008W/520110008W_warning%20letter_02252011.pdf

520110008W_warning letter_02252011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110008W/520110008W_warning%20letter_02252011_text.pdf

520110008W_warning letter_02252011_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 25, 2011
Mr. Carlos Fandino
Director
City of Vernon
Light and Power Department
4305 Santa Fe Avenue
Vernon, CA 90058
CPF 5-2011-0008W
Dear Mr. Fandino:
On August 16 to 19, and on November 3, 2010, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
inspected manuals and records, and conducted a field audit of your pipeline facilities in Vernon,
California.
As a result of the inspection, it appears that the City of Vernon has committed a probable
violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item
inspected and the probable violation is:
1. § 192.625 Odorization of gas.
(f) To assure the proper concentration of odorant in accordance with this section,
each operator must conduct periodic sampling of combustible gases using an
instrument capable of determining the percentage of gas in air at which the odor
becomes readily detectable. Operators of master meter systems may comply with
this requirement by-
(1) Receiving written verification from their gas source that the gas has the proper



concentration of odorant; and
(2) Conducting periodic "sniff" tests at the extremities of the system to confirm that
the gas contains odorant.
The City of Vernon is not assuring the proper concentration of odorant as required by
§192.625(f). The City Operations, Inspection, and Maintenance Plans (May 27, 2010 revision)
contains procedures to assure proper concentration of odorant, but the procedures have not been
implemented. Historically, odorization has been provided by SoCal Gas Company and
supporting odorant concentration confirmation records were provided to the City of Vernon in
the past. However, no recent records from SoCal Gas Company were available at the time of the
inspection. Additionally, The City of Vernon has not been conducting any periodic “sniff” tests
at the extremities of the system to confirm that the gas contains odorant.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000
for each violation for each day the violation persists up to a maximum of $1,000,000 for any
related series of violations. We have reviewed the circumstances and supporting documents
involved in this case, and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to correct the item identified in this letter.
Failure to do so will result in City of Vernon Light and Power Department being subject to
additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 5-2011-0008W. 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).
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 P. Nguyen (#128473)

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520110008W>
- Source ID: `phmsa-enforcement`
- SHA-256: `e722b9a5b9906d49567647a57be99062fa1356206b76981400df9b4c3184bd47`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T20:03:33.668Z
- Document slug: `phmsa-enforcement-520110008w`

### Source metadata

```json
{
  "cpf": "520110008W",
  "operator": "CITY OF VERNON",
  "region": "Western",
  "pipelineType": "GAS INTRASTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.625(f)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
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      "name": "520110008W_warning letter_02252011.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520110008W/520110008W_warning%20letter_02252011.pdf",
      "bytes": 123083,
      "category": "agency_document"
    },
    {
      "name": "520110008W_warning letter_02252011_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520110008W/520110008W_warning%20letter_02252011_text.pdf",
      "bytes": 18722,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "CITY OF VERNON"
}
```
