{"operation":"document","citation":"CPF 120200006M","title":"PACIFIC GAS & ELECTRIC CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-06-12","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120200006m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120200006m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120200006m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120200006M","body":"Notice of Amendment involving PACIFIC GAS & ELECTRIC CO. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2020-06-12 and is reported as closed as of 2020-09-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120200006M_Closure Letter_09102020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120200006M/120200006M_Closure%20Letter_09102020.pdf\n\n120200006M_Closure Letter_09102020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120200006M/120200006M_Closure%20Letter_09102020_text.pdf\n\n120200006M_Notice of Amendment_06122020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120200006M/120200006M_Notice%20of%20Amendment_06122020.pdf\n\n120200006M_Notice of Amendment_06122020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120200006M/120200006M_Notice%20of%20Amendment_06122020_text.pdf\n\n120200006M_Operator Response to Notice_07102020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120200006M/120200006M_Operator%20Response%20to%20Notice_07102020.pdf\n\n120200006M_Closure Letter_09102020_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nSeptember 10, 2020\nMr. William D. Johnson\nPresident\nPacific Gas and Electric Company\nPO Box 770000 Mail Code H15B\nSan Francisco, CA 94105\nCPF 1-2020-0006M\nDear Mr. Johnson:\nFrom November 19 – 22, 2019, inspectors from the California Geologic Energy Management\nDivision (CalGEM), acting as an Agent for the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.) inspected Pacific Gas & Electric Company’s (PG&E) procedures relevant to\nits underground natural gas storage program for the Pleasant Creek (PC) and McDonald Island\n(MI) intrastate underground natural gas storage (UNGS) facilities in San Joaquin and Yolo\nCounties, California. As a result of the inspection, PG&E was issued a Notice of Amendment on\nJune 12, 2020, which proposed amendment of your procedures.\nPG&E submitted its amended procedures on or about July 10, 2020. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120200006M_Notice of Amendment_06122020_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJune 12, 2020\nMr. William D. Johnson\nPresident\nPacific Gas and Electric Company\nPO Box 770000 Mail Code H15B\nSan Francisco, CA 94105\nCPF 1-2020-0006M\nDear Mr. Johnson:\nFrom November 19 – 22, 2019, inspectors from the California Geologic Energy Management\nDivision (CalGEM), acting as an Agent for the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.) inspected Pacific Gas & Electric Company (PG&E)’s procedures relevant to\nits underground natural gas storage program for the Pleasant Creek (PC) and McDonald Island\n(MI) intrastate underground natural gas storage (UNGS) facilities in San Joaquin and Yolo\nCounties, California.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nPG&E’s plans or procedures, as described below:\n1. § 192.605 Procedural manual for operations, maintenance and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a\nmanual of written procedures for conducting operations and\nmaintenance activities and for emergency response. For transmission\nlines, the manual must also include procedures for handling abnormal\noperations. This manual must be reviewed and updated by the operator\nat intervals not exceeding 15 months, but at least once each calendar\nyear. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\n\n\n\nCPF 1-2020-0006M\nPG&E’s procedures for reporting safety related conditions were inadequate. Specifically, PG&E’s\nprocedure TD 4413P02 only required PG&E to notify California Public Utility Commission (PUC)\nof safety related conditions reports (SRCRs) at UNGS facilities rather than notifying CalGEM for\nUNGS SRCRs. CalGEM is the state entity that has entered into an Agreement with PHMSA to\nperform safety inspections of intrastate UNGS facilities within the state of California.\nAt the time of the inspection, CalGEM discovered that PG&E’s procedures did not require\nnotification of UNGS SRCRs to be provided to CalGEM, as required by § 191.7(c)1\n.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Pacific Gas & Electric Company maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nPHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Please refer\nto CPF 1-2020-0006M on each document you submit, and whenever possible provide a signed\nPDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger\nfiles should be sent on USB flash drive accompanied by the original paper copy to the Eastern\nRegion Office.\n1 Section 191.7(c) states:\n(c) Safety-related conditions. An operator must submit concurrently to the applicable State agency a safety-related\ncondition report required by § 191.23 for intrastate pipeline transportation or when the State agency acts as an agent\nof the Secretary with respect to interstate transmission facilities.\n120200006M_Notice of Amendment_06122020_text Page 2 of 3\n\n\n\nCPF 1-2020-0006M\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\nCC: Nick Stavropoulos, Executive Vice President, Gas Operations, Pacific Gas and Electric\nCompany (via email)\nMike Bradley, Senior Manager, Gas Ops Compliance, Pacific Gas and Electric Company\n(via email)\n120200006M_Notice of Amendment_06122020_text Page 3 of 3","truncated":false,"body_characters":8249}