{"operation":"document","citation":"CPF 12022061WL","title":"PACIFIC GAS & ELECTRIC CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-08-03","effective_on":null,"summary":"CLOSED warning letter citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022061wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022061wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022061wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022061WL","body":"Warning Letter involving PACIFIC GAS & ELECTRIC CO. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2022-08-03 and is reported as closed as of 2022-08-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022061WL_Warning Letter_08032022_(21-231776).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022061WL/12022061WL_Warning%20Letter_08032022_(21-231776).pdf\n\n12022061WL_Warning Letter_08032022_(21-231776)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022061WL/12022061WL_Warning%20Letter_08032022_(21-231776)_text.pdf\n\n12022061WL_Warning Letter_08032022_(21-231776)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: pkpc@pge.com\nAugust 3, 2022\nMs. Patti Poppe\nPresident and Chief Executive Officer\nPacific Gas & Electric Co\n3301 Crow Canyon Road\nSan Ramon, California 94583\nCPF 1-2022-061-WL\nDear Ms. Poppe:\nFrom November 8th, 2021 to November 15th 2021, 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 Co’s (PGE) procedures for Pleasant Creek, McDonald\nIsland and Los Medanos Storage facilities in Yolo County, San Joaquin County, and Contra Costa\nCounty California, respectively.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\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\nmust have written procedures in place before commencing\noperations or beginning an activity not yet implemented.\nPGE failed to follow its manual of written procedures for conducting operations, maintenance, and\nemergency preparedness and response activities. Specifically, PGE failed to follow its\nUnderground Storage Risk and Integrity Management Plan, Appendix L, Practice 8 – Annular Pressure\nand Gas Sampling Monitoring, Revision 5 dated 3/29/19 (Annular Pressure Procedure), regarding\ndocumenting trending, analysis, and recommendations for addressing annular pressure.\nDuring the inspection, CalGEM identified that two wells have had higher annular pressures since\n2016. When requested, PGE was unable to provide records indicating that steps 6 and 7 from its\nAnnular Pressure Procedure were followed. Under PGE’s procedure, step 6 requires that a\nreservoir engineer trend the pressure and document the analysis work. Step 7 of the procedure\nrequires the recommendations from the reservoir engineer to be documented on how to address\nthe annular pressure. Specifically, records did not indicate that the annular pressure and gas\nsamples were reviewed and recorded by a reservoir engineer as stated within the operator’s\nprocedures.\nTherefore, PGE failed to follow its Annular Pressure Procedure as required by § 192.12(c).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for a related\nseries of violations. For violation occurring on or after May 3, 2021 and before March 21, 2022,\nthe maximum penalty may not exceed $225,134 per violation per day the violation persists, up to\na maximum of $2,251,334 for a related series of violations. For violation occurring on or after\nJanuary 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per\nviolation per day the violation persists, up to a maximum of $2,225,034 for a related series of\nviolations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the\nmaximum penalty may not exceed $218,647 per violation per day the violation persists, up to a\nmaximum of $2,186,465 for a related series of violations. For violation occurring on or after\nNovember 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per\nviolation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on\nor after November 2, 2015, and before November 27, 2018, the maximum penalty may not exceed\n$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in\nPacific Gas & Electric Co being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2022-061-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\n\n\n\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":6096}