{"operation":"document","citation":"CPF 12022002NOA","title":"PACIFIC GAS & ELECTRIC CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-01-28","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c), 192.12(d)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022002noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022002noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022002noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022002NOA","body":"Notice of Amendment involving PACIFIC GAS & ELECTRIC CO. PHMSA's enforcement data identifies the cited regulations as 192.12(c),  192.12(d)(4). The case was opened on 2022-01-28 and is reported as closed as of 2022-06-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022002NOA_Closure Letter_06282022_(20-197396).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022002NOA/12022002NOA_Closure%20Letter_06282022_(20-197396).pdf\n\n12022002NOA_Closure Letter_06282022_(20-197396)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022002NOA/12022002NOA_Closure%20Letter_06282022_(20-197396)_text.pdf\n\n12022002NOA_Notice of Amendment_01282022_(20-197396).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022002NOA/12022002NOA_Notice%20of%20Amendment_01282022_(20-197396).pdf\n\n12022002NOA_Notice of Amendment_01282022_(20-197396)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022002NOA/12022002NOA_Notice%20of%20Amendment_01282022_(20-197396)_text.pdf\n\n12022002NOA_Operator Response to Notice_02252022_(20-197396).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022002NOA/12022002NOA_Operator%20Response%20to%20Notice_02252022_(20-197396).pdf\n\n12022002NOA_Notice of Amendment_01282022_(20-197396)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: JXQV@pge.com\nJanuary 28, 2022\nMs. Janisse Quinones\nSVP, Gas Engineering\nPacific Gas & Electric\n6121 Bollinger Canyon Rd\nSan Ramon, CA 94583\nCPF 1-2022-002-NOA\nDear Ms. Quinones:\nFrom November 17, 2020 through November 21, 2020, an inspector from the California Geologic\nEnergy Management Division (CalGEM), acting as an agent for the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected Pacific Gas & Electric Company’s (PGE) procedures for McDonald Island,\nPleasant Creek, and Los Medanos underground natural gas storage (UNGS) facilities located in\nSan Joaquin, Yolo, and Contra Costa counties, California, respectively.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies found within PGE’s\nprocedures, as described below:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\n\n\n\nCPF 1-2022-002-NOA\nmust have written procedures in place before commencing\noperations or beginning an activity not yet implemented.\nPGE’s written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities were inadequate to ensure safe operation of a pipeline facility. Specifically,\nPGE’s Underground Storage Risk and Integrity Management Plan (USRIMP) did not include a\nprocess for using portable concrete pedestals for well signage in lieu of permanent signage in\naccordance with API RP 1171, Section 10.4.1, Minimum Signage Information.\n1\nDuring the inspection, CalGEM reviewed PGE’s USRIMP, appendix AF and found that PGE did\nnot include a process for using portable concrete pedestals for well signage in lieu of permanent\nwell signage. PGE’s McDonald Island has limited space at the well sites. Thus, portable concrete\npedestals for well signage are used so they can be temporarily moved while performing well work.\nThe use of portable well signs may result in a well being misidentified without a process to address\nthe handling of the portable well signs.\nTherefore, PGE’s written procedures required by § 192.12(c) were inadequate. PGE must revise\nits procedures to address using portable well signage in lieu of permanent signage in accordance\nwith Section 10.4.1.\n2. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\nPGE’s written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities were inadequate to ensure safe operation of a pipeline facility. Specifically,\nPGE’s USRIMP did not include procedures for interacting and communicating with a control room\nduring normal, abnormal, and emergency conditions in accordance with API RP 1171, Sections\n11.7.1 and 11.7.2.2\n1 API RP 1171, Section 10.4.1, Minimum Signage Information\nPermanent weatherproof signage shall be installed at each well site for identification purposes….\n2 API RP 1171, Section 11.7.1, General\nStorage personnel shall be responsible for preparing and communicating guidelines for maintaining reservoir and\nwell functional integrity.\nAPI RP 1171, Section 11.7.2, Scope of Procedures\n12022002NOA_Notice of Amendment_01282022_(20-197396)_text Page 2 of 5\n\n\n\nCPF 1-2022-002-NOA\nDuring the inspection, CalGEM reviewed PGE’s USRIMP. CalGEM found that PGE did not have\nguidelines for interaction and communication with a control room to maintain reservoir and well\nfunctional integrity during normal, abnormal, and emergency conditions.\nTherefore, PGE’s written procedures required by § 192.12(c) were inadequate. PGE must revise\nits procedures to include guidelines for interacting and communicating with a control room to\nmaintain reservoir and well functional integrity during normal, abnormal, and emergency\nconditions in accordance with Sections 11.7.1 and 11.7.2.\n3. § 192.12 Underground natural gas storage facilities.\n(a) …\n(d) Integrity management program--\n(1) …\n(4) Integrity management procedures and recordkeeping. Each\nUNGSF operator must establish and follow written procedures to carry\nout its integrity management program under API RP 1171\n(incorporated by reference, see § 192.7), section 8 (\"Risk Management\nfor Gas Storage Operations\"), and this paragraph (d). The operator\nmust also maintain, for the useful life of the UNGSF, records that\ndemonstrate compliance with the requirements of this paragraph (d).\nThis includes records developed and used in support of any\nidentification, calculation, amendment, modification, justification,\ndeviation, and determination made, and any action taken to implement\nand evaluate any integrity management program element.\nPGE’s written procedures for carrying out its integrity management program were inadequate to\nensure safe operation of a pipeline facility. Specifically, PGE’s USRIMP did not include detailed\ninformation about the data used to determine susceptibility to threat and hazard-related events in\naccordance with API RP 1171, Section 8.3.2.3\nDuring the inspection, CalGEM reviewed PGE’s USRIMP. PGE did not list detailed information\nabout the data used to determine susceptibility to threat and hazard-related events or refer to where\nthe specific data is contained.\nTherefore, PGE’s written procedures required by § 192.12(d)(4) were inadequate. PGE must\nrevise its procedures to include detailed information about the data used to determine susceptibility\nto threat and hazard-related events in accordance with Section 8.3.2.\nThe operator should establish procedures for interaction and communication with a control room, including\nauthority for initiating flow, operating, and shutting in natural gas storage facilities as required in order to maintain\nreservoir and well integrity during normal, abnormal, and emergency conditions.\n3 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.\n12022002NOA_Notice of Amendment_01282022_(20-197396)_text Page 3 of 5\n\n\n\nCPF 1-2022-002-NOA\n4. § 192.12 Underground natural gas storage facilities.\n(a) …\n(d) Integrity management program--\n(1) …\n(4) Integrity management procedures and recordkeeping. Each\nUNGSF operator must establish and follow written procedures to carry\nout its integrity management program under API RP 1171\n(incorporated by reference, see § 192.7), section 8 (\"Risk Management\nfor Gas Storage Operations\"), and this paragraph (d). The operator\nmust also maintain, for the useful life of the UNGSF, records that\ndemonstrate compliance with the requirements of this paragraph (d).\nThis includes records developed and used in support of any\nidentification, calculation, amendment, modification, justification,\ndeviation, and determination made, and any action taken to implement\nand evaluate any integrity management program element.\nPGE’s written procedures for carrying out its integrity management program were inadequate to\nensure safe operation of a pipeline facility. Specifically, PGE’s USRIMP did not include wildfires\nor the single access point to the McDonald Island UNGS facility as threats or hazard in accordance\nwith API RP 1171, Section 8.4.2.4\nDuring the inspection, CalGEM reviewed PGE’s USRIMP. PGE did not include threats and\nhazards from wildfires or the single access point to the McDonald Island UNGS facility in its\nintegrity management program.\nTherefore, PGE’s written procedures required by § 192.12(d)(4) were inadequate. PGE must\nrevise its procedures to include the threats and hazards specified in the previous paragraph in\naccordance with Section 8.4.2.\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\npart of 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\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. 552(b).\n4 API RP 1171, Section 8.4.2, Methodology\nThe operator shall evaluate the potential threats and hazards impacting storage wells and reservoirs….\n12022002NOA_Notice of Amendment_01282022_(20-197396)_text Page 4 of 5\n\n\n\nCPF 1-2022-002-NOA\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,\nEastern Region, Pipeline and Hazardous Materials Safety Administration, 840 Bear Tavern Road,\nSuite 300, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF\n1-2022-002-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should\nbe sent on USB flash drive accompanied by 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\n12022002NOA_Notice of Amendment_01282022_(20-197396)_text Page 5 of 5\n\n12022002NOA_Closure Letter_06282022_(20-197396)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJune 28, 2022\nMs. Janisse Quinones\nSenior Vice President, Gas Engineering\nPacific Gas & Electric\n6111 Bollinger Canyon Rd\nSan Ramon, CA 94583\nCPF 1-2022-002-NOA\nDear Ms. Quinones:\nFrom November 17, 2020, through November 21, 2020, an inspector from the California Geologic\nEnergy Management Division (CalGEM), acting as an agent for the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected Pacific Gas & Electric Company’s (PGE) procedures for McDonald Island,\nPleasant Creek, and Los Medanos underground natural gas storage (UNGS) facilities located in\nSan Joaquin, Yolo, and Contra Costa counties, California, respectively. As a result of the\ninspection, PGE was issued a Notice of Amendment on January 28, 2022, which proposed\namendment of your procedures.\nPGE submitted its amended procedures on February 25, 2022 and May 13, 2022. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have 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","truncated":false,"body_characters":14789}