{"operation":"document","citation":"CPF 12021073NOA","title":"SOUTHERN CALIFORNIA GAS CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-12-16","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(d)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021073noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021073noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021073noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021073NOA","body":"Notice of Amendment involving SOUTHERN CALIFORNIA GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.12(d)(4). The case was opened on 2021-12-16 and is reported as closed as of 2022-02-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021073NOA_Closure Letter_02222022_(20-197117).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021073NOA/12021073NOA_Closure%20Letter_02222022_(20-197117).pdf\n\n12021073NOA_Closure Letter_02222022_(20-197117)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021073NOA/12021073NOA_Closure%20Letter_02222022_(20-197117)_text.pdf\n\n12021073NOA_Notice of Amendment_12162021_(20-197117).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021073NOA/12021073NOA_Notice%20of%20Amendment_12162021_(20-197117).pdf\n\n12021073NOA_Notice of Amendment_12162021_(20-197117)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021073NOA/12021073NOA_Notice%20of%20Amendment_12162021_(20-197117)_text.pdf\n\n12021073NOA_Operator Response to Notice_01272022_(20-197117).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021073NOA/12021073NOA_Operator%20Response%20to%20Notice_01272022_(20-197117).pdf\n\n12021073NOA_Closure Letter_02222022_(20-197117)_text.pdf\n\nVIA ELECTRONIC MAIL TO: SDrury@socalgas.com\nFebruary 22, 2022\nMr. Scott Drury\nChief Executive Officer\nSouthern California Gas Company\n555 W. Fifth Street\nLos Angeles, California 90013\nCPF 1-2021-073-NOA\nDear Mr. Drury:\nFrom October 20, 2020 to October, 23, 2020, California Geologic Energy Management Division\n(CalGEM), acting as an agent for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Southern\nCalifornia Gas Company’s (SCG) procedures for their Aliso Canyon, Honor Rancho, and Playa\nDel Rey Underground Natural Gas Storage Facilities (UNGSF) located in Los Angeles County,\nCalifornia and their La Goleta UNGSF located in Santa Barbara County, California.\nSCG submitted its amended procedures on January 27, 2022. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\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\n12021073NOA_Notice of Amendment_12162021_(20-197117)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nDecember 16, 2021\nMr. Scott Drury\nChief Executive Officer\nSouthern California Gas Company\n555 W. Fifth Street\nLos Angeles, California 90013\nCPF 1-2021-073-NOA\nDear Mr. Drury:\nFrom October 20, 2020 to October, 23, 2020, California Geologic Energy Management Division\n(CalGEM), acting as an agent for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Southern California\nGas Company’s (SCG) procedures for their Aliso Canyon, Honor Rancho, and Playa Del Rey\nUnderground Natural Gas Storage Facilities (UNGSF) located in Los Angeles County, California and\ntheir La Goleta UNGSF located in Santa Barbara County, California.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within SCG’s\nprocedures, as described below:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(d) Integrity management program—\n(1) …\n(4) Integrity management procedures and recordkeeping. Each UNGSF\noperator must establish and follow written procedures to carry out its\nintegrity management program under API RP 1171 (incorporated by\nreference, see § 192.7), section 8 (\"Risk Management for Gas Storage\nOperations\"), and this paragraph (d). The operator must also maintain,\nfor the useful life of the UNGSF, records that demonstrate compliance\nwith the requirements of this paragraph (d). This includes records\ndeveloped and used in support of any identification, calculation,\namendment, modification, justification, deviation, and determination\nmade, and any action taken to implement and evaluate any integrity\nmanagement program element.\n\n\n\nCPF 1-2021-073-NOA\nSCG’s written procedures for carrying out its integrity management program under API RP 1171,\nSection 8 were inadequate to ensure safe operation of a pipeline facility. Specifically, SCG’s Storage\nIntegrity Management Plan 2 (SIMP2) did not provide specific information to be collected and used\nto assess threat and hazard interactions in accordance with API RP 1171, Section 8.3.2 (Section 8.3.2).1\nDuring the inspection, CalGEM reviewed SCG’s SIMP2 procedure. The SIMP2 procedure stated in\npart:\nSoCalGas has identified appropriate sources of information for the required data elements.\nThe data sources are typically associated with design, construction, operational, or\nmaintenance records in compliance with the Sempra’s Information Management Policy. The\nfollowing databases are utilized to capture data:\n3.2.1. WellView: A well data management system containing data related to planning,\ndrilling, completion, abandonment, testing and workovers.\n3.2.2. RigView: A rig and well project scheduling system for drilling, completions,\nworkovers and testing.\n3.2.3. OSI Soft PI: The repository for process information such as storage field injection and\nwithdrawal rates, and well pressures.\n3.2.4. Maximo: The maintenance management system for storage facilities. Inspection\nactivities for the following well components are scheduled and recorded in Maximo:\n3.2.4.1. Wellhead valve\n3.2.4.2. Surface safety valve\n3.2.4.3. Surface-controlled subsurface safety valve\n3.2.5. SAP: Invoice management system.\n3.2.6. Petrel: Geology software platform.\nSCG’s SIMP2 procedure identified appropriate sources of information under Section 8.3.2 but did not\nsufficiently specify what data and information would, at a minimum, be collected from these sources\nand used to assess threat and hazard interactions. Additionally, SCG’s SIMP2 procedure currently\nstates that the data collected will be used to “determine susceptibility to threat and hazard-related events\nand to assess threat interaction.”2 Section 8.3.2 requires operators to use available information to\ndetermine susceptibility to threat and hazard-related events and assess threat and hazard interaction.\nSCG must amend its procedures to clarify that the data collected under Section 3 of the SIMP2\nprocedure will be used to assess threat and hazard interactions.\n1 API RP 1171, Section 8.3.2 Data Sources\nThe operator shall use available information such as performance data collected through the field history, operations\nand maintenance (O&M) activities, geotechnical data such as well logs, engineering data, and completion reports to\ndetermine susceptibility to threat and hazard-related events and to assess threat and hazard interaction.\n2 SIMP2, 3. Data Collection, at 4 (on file with PHMSA).\n12021073NOA_Notice of Amendment_12162021_(20-197117)_text Page 2 of 3\n\n\n\nCPF 1-2021-073-NOA\nTherefore, SCG’s written procedures, required by § 192.12(d)(4), were inadequate. SCG must revise\nits procedures to more clearly specify what information will be collected and used to assess threat and\nhazard interaction in accordance with Section 8.3.2.\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 part\nof this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you submit\nin response to this enforcement action is subject to being made publicly available. If you believe that\nany portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document with the\nportions you believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised procedures,\nor a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this\nNotice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes\nthe Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further\nnotice to you and to issue an Order Directing Amendment. If your plans or procedures are found\ninadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct\nthe inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you\nsubmit your amended procedures to my office within 30 days of receipt of this Notice. This period\nmay be extended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Southern California Gas Company maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration, 840 Bear Tavern Road, Suite 300, West Trenton, NJ\n08628. In correspondence concerning this matter, please refer to CPF 1-2021-073-NOA and, for each\ndocument you submit, please provide a copy in electronic format whenever possible. Smaller files may\nbe emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive accompanied\nby the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12021073NOA_Notice of Amendment_12162021_(20-197117)_text Page 3 of 3","truncated":false,"body_characters":10163}