{"operation":"document","citation":"CPF 12022052NOA","title":"SOUTHERN CALIFORNIA GAS CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-05-10","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022052noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022052noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022052noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022052NOA","body":"Notice of Amendment involving SOUTHERN CALIFORNIA GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2022-05-10 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\n12022052NOA_Closure Letter_06282022_(21-231340).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022052NOA/12022052NOA_Closure%20Letter_06282022_(21-231340).pdf\n\n12022052NOA_Closure Letter_06282022_(21-231340)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022052NOA/12022052NOA_Closure%20Letter_06282022_(21-231340)_text.pdf\n\n12022052NOA_Notice of Amendment_05102022_(21-231340).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022052NOA/12022052NOA_Notice%20of%20Amendment_05102022_(21-231340).pdf\n\n12022052NOA_Notice of Amendment_05102022_(21-231340)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022052NOA/12022052NOA_Notice%20of%20Amendment_05102022_(21-231340)_text.pdf\n\n12022052NOA_Operator Response to Notice_06152022_(21-231340).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022052NOA/12022052NOA_Operator%20Response%20to%20Notice_06152022_(21-231340).pdf\n\n12022052NOA_Notice of Amendment_05102022_(21-231340)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nMay 10, 2022\nMr. Scott Drury\nPresident and Chief Executive Officer\nSouthern California Gas Co\n555 West Fifth Street\nLos Angeles, California 90013\nCPF 1-2022-052-NOA\nDear Mr. Drury:\nFrom October 11 through 15, 2021, an inspector from the California Geologic Energy\nManagement Division (CalGEM), acting as an agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected Southern California Gas Company’s (SCG) procedures for its Aliso Canyon, Honor\nRancho, and Playa Del Rey Underground Natural Gas Storage Facilities (UNGSF) located in Los\nAngeles County, California and its La Goleta UNGSF located in Santa Barbara County, California.\nOn the basis of the inspection, PHMSA has identified an apparent inadequacy found within SCG’s\nplans or procedures, 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 1-2022-052-NOA\nmust have written procedures in place before commencing\noperations.\nSCG’s written procedures for conducting maintenance and normal operations were inadequate to\nensure safe operation of a pipeline facility. Specifically, SCG’s Gas Standard 224.0000 Testing\nand Inspection of Safety Valves and Wellhead Valves (Standard 224.0000) did not include the\nactions that must be taken if manual wellhead valves required repair or replacement in accordance\nwith API RP 1171, Section 9.3.2 (Section 9.3.2).\nSection 9.3.2 states, in part, that “[t]he valves shall be maintained, repaired, or replaced in\naccordance with the operator’s valve maintenance program for isolation valves.”\nDuring the inspection, CalGEM reviewed SCG’s Standard 224.0000, Section 6.4 (Section 6.4) and\nSection 6.5 (Section 6.5). Section 6.4 stated, in part, “[i]ssue a corrective maintenance order (CM)\nfor any unresolved substandard conditions,” while Section 6.5 stated, in part, “[a]dditional\nmaintenance, repair or replacement of wellhead valves shall be planned and scheduled as needed.\n”\nHowever, no additional actions were included in the written procedures that specified how to repair\nor replace manual wellhead valves.\nTherefore, SCG’s written procedures were inadequate to ensure safe operation of a pipeline facility\nin accordance with § 192.12(c). SCG must revise its written procedures to include the actions that\nmust be taken if manual wellhead valves require repair or replacement.\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\nthe document 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).\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\n12022052NOA_Notice of Amendment_05102022_(21-231340)_text Page 2 of 3\n\n\n\nCPF 1-2022-052-NOA\naction will be closed.\nIt is requested (not mandated) that Southern California Gas Co maintain documentation of the\nsafety 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\n1-2022-052-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\n12022052NOA_Notice of Amendment_05102022_(21-231340)_text Page 3 of 3\n\n12022052NOA_Closure Letter_06282022_(21-231340)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJune 28, 2022\nMr. Scott Drury\nPresident and Chief Executive Officer\nSouthern California Gas Co\n555 West Fifth Street\nLos Angeles, California 90013\nCPF 1-2022-052-NOA\nDear Mr. Drury:\nFrom October 11 through 15, 2021 an inspector from the California Geologic Energy Management\nDivision (CalGEM), acting as an agent for the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nSouthern California Gas Company’s (SCG) procedures for its Aliso Canyon, Honor Rancho, and\nPlaya Del Rey Underground Natural Gas Storage Facilities (UNGSF) located in Los Angeles\nCounty, California and its La Goleta UNGSF located in Santa Barbara County, California. As a\nresult of the inspection, SCG was issued a Notice of Amendment on May 10, 2022, which proposed\namendment of your procedures.\nSCG submitted its amended procedures on June 15, 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","truncated":false,"body_characters":8605}