# COALINGA, CITY OF — Warning Letter

**Citation:** CPF 520200002W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2020-02-28

CLOSED warning letter citing 192.603(b), 192.605(a), 192.605(b)(1).

## Document text

Warning Letter involving COALINGA, CITY OF. PHMSA's enforcement data identifies the cited regulations as 192.603(b),  192.605(a),  192.605(b)(1). The case was opened on 2020-02-28 and is reported as closed as of 2020-02-28. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520200002W_Warning Letter_02282020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520200002W/520200002W_Warning%20Letter_02282020.pdf

520200002W_Warning Letter_02282020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520200002W/520200002W_Warning%20Letter_02282020_text.pdf

520200002W_Warning Letter_02282020_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 28, 2020
Ms. Marissa Trejo
City Manager
City of Coalinga
155 West Durian
Coalinga, CA 93210
CPF 5-2020-0002W
Dear Ms. Trejo:
On September 4 through 10, 2019, a representative of the California Public Utilities
Commission (CPUC) on behalf of the Pipeline and Hazardous Materials Safety Administration
(PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected the City of Coalinga’s
(Coalinga) gas distribution system procedures and records.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items
inspected and the probable violations are:
1. § 192.603 General provisions.
(a)…
(b) Each operator shall keep records necessary to administer the procedures
established under §192.605.



Coalinga did not keep records necessary to administer the procedures established under
§192.605 in two instances:
(1) Coalinga was unable to provide records documenting the training required by
§192.615(b)(2); and
(2) Coalinga was unable to provide records to show that patrolling was conducted at
the frequency required by §192.721(b).
2. §192.605 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response…
(b) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance with each of
the requirements of this subpart and subpart M of this part.
Coalinga failed to follow its manual of written procedures with regard to operating,
maintaining and repairing the pipeline in accordance with each of the requirements in subpart
M of Part 192. Specifically, Coalinga failed to check and service each distribution system
valve which may be necessary for the safe operation of a distribution system at an interval not
exceeding 15-months but at least once each calendar year pursuant to § 192.747(a). On
September 10, 2019, Coalinga’s records indicated that the valves were last serviced on May
14, 2018.
Under 49 U.S.C. §60122 and 49 CFR §190.223, you are subject to a civil penalty not to
exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465
for a related series of violations. For violation occurring on or after November 27, 2018 and
before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day,
with a maximum penalty not to exceed $2,132,679. For violation occurring on or after
November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed
$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. For
violations occurring prior to November 2, 2015, the maximum penalty may not exceed
$200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a
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 items identified in this
letter. Failure to do so will result in Coalinga being subject to additional enforcement action.
2



No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2020-0002W. Please copy the CPUC Program Manager on all correspondence. 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,
Dustin Hubbard
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Dunphy (#165838)
Terrence Eng, Program Manager, Gas Safety and Reliability Branch
California Public Utilities Commission
3

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520200002W>
- Source ID: `phmsa-enforcement`
- SHA-256: `b237999f9cfb14f2558b2dba7de40d4e3a48cb042f29e951cc6d25125483b2b6`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-24T15:38:49.175Z
- Document slug: `phmsa-enforcement-520200002w`

### Source metadata

```json
{
  "cpf": "520200002W",
  "operator": "COALINGA, CITY OF",
  "region": "Western",
  "pipelineType": "GAS INTRASTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.603(b)",
    "192.605(a)",
    "192.605(b)(1)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
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      "bytes": 990400,
      "category": "agency_document"
    },
    {
      "name": "520200002W_Warning Letter_02282020_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520200002W/520200002W_Warning%20Letter_02282020_text.pdf",
      "bytes": 123079,
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    }
  ],
  "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": "COALINGA, CITY OF"
}
```
