{"operation":"document","citation":"CPF 12022062NOA","title":"PACIFIC GAS & ELECTRIC CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-08-18","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022062noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022062noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022062noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022062NOA","body":"Notice of Amendment involving PACIFIC GAS & ELECTRIC CO. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2022-08-18 and is reported as closed as of 2023-02-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022062NOA_Closure Letter_02022023_(21-231776).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022062NOA/12022062NOA_Closure%20Letter_02022023_(21-231776).pdf\n\n12022062NOA_Closure Letter_02022023_(21-231776)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022062NOA/12022062NOA_Closure%20Letter_02022023_(21-231776)_text.pdf\n\n12022062NOA_Notice of Amendment_08182022_(21-231776).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022062NOA/12022062NOA_Notice%20of%20Amendment_08182022_(21-231776).pdf\n\n12022062NOA_Notice of Amendment_08182022_(21-231776)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022062NOA/12022062NOA_Notice%20of%20Amendment_08182022_(21-231776)_text.pdf\n\n12022062NOA_Operator RtN and Request Case Closure_10272022_(21-231776).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022062NOA/12022062NOA_Operator%20RtN%20and%20Request%20Case%20Closure_10272022_(21-231776).pdf\n\n12022062NOA_Notice of Amendment_08182022_(21-231776)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nAugust 18, 2022\nMs. Patti Poppe\nPresident and Chief Executive Officer\nPacific Gas & Electric Co\n3301 Crow Canyon Road\nSan Ramon, California 94583\nCPF 1-2022-062-NOA\nDear Ms. Poppe:\nFrom November 8, 2021, through November 15, 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\ninspected Pacific Gas & Electric Co’s (PGE) procedures for Pleasant Creek, McDonald Island and\nLos Medanos Storage facilities in Yolo County, San Joaquin County, and Contra Costa County\n(respectively) California.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nPGE’s plans 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\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 (RIMP) were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, PGE’s RIMP, Section 9 Mechanical Integrity of the Wells failed to describe in\nsufficient detail the process for selecting an integrity assessment methodology and frequencies\nwhen each methodology would be used as required by API RP 1171 Section 9.3.1 (Section 9.3.1).\nSection 9.3.1 states in part that “[a]ctive well mechanical integrity evaluations shall include initial\nand subsequent evaluations as determined using the risk assessment and the information derived\nfrom the initial evaluation.”\nAt the time of the inspection, PGE’s written procedures for well integrity evaluation only listed\ndifferent types of potential integrity evaluations that PGE can perform but did not describe a\nselection process and a frequency for each type of evaluation. The process should include criteria\nfor selection of evaluation, and frequencies for evaluations based on the risk assessments.\nTherefore, PGE’s written procedures for conducting operations, maintenance, and emergency\npreparedness and response activities were inadequate to ensure safe operation of a pipeline facility\nin accordance with § 192.12(c). PGE must revise its procedures to include adequate detail for\nselecting and implementing its various integrity assessment methodologies.\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 Underground Storage Risk and Integrity Management Plan, RIMP Section 6, failed to\ndescribe in sufficient detail each process PGE follows to maintain ongoing functional integrity of\nits reservoirs as required by API RP 1171, Section 9.2.1 (Section 9.2.1).\nSection 9.2.1 states in part,\n“[t]he operator shall maintain functional integrity of storage wells and\nreservoirs. Storage wells and reservoirs can have different characteristics resulting in unique\nrequirements in approaching integrity demonstration, verification, and monitoring.”\n\n\n\nAt the time of the inspection, PGE’s written procedures for functional integrity of the reservoirs\nwas inadequate because PGE failed to describe the integrity work in detail. The procedures\npresented during the inspection only listed different integrity management processes used by PGE\nto demonstrate functional integrity of the reservoirs but were not descriptive of the processes.\nTherefore, PGE’s written procedures for conducting operations, maintenance, and emergency\npreparedness and response activities were inadequate to ensure safe operation of a pipeline facility\nin accordance with § 192.12(c). PGE must revise its procedures to include adequate detail\nregarding its processes for maintaining ongoing functional integrity of its reservoirs.\n3. § 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 RIMP, Section 11 Safety Valve Operation, Maintenance and Inspection, did not include a\nrequirement to perform a physical inspection of a closed safety valve in order for it to be reopened,\nin accordance with PGE’s practices in the field.\nDuring the inspection, PGE provided CalGEM with procedures and question responses stating that\nits storage well safety valves can be opened manually at the wellhead or from the control pad on\nthe well pad. The written procedures in place at the time of the inspection did not include a\nrequirement that an observer be present at the wellhead during safety valve re-opening in order to\ninspect for abnormalities, which was identified by PGE to be its practice in the field.\nTherefore, PGE’s written procedures for conducting operations, maintenance, and emergency\npreparedness and response activities were inadequate to ensure safe operation of a pipeline facility\nin accordance with § 192.12(c). PGE must revise its procedures to be consistent with their field\npractices.\n4. § 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\n\n\n\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 RIMP, Section 12 Wellhead (Christmas Tree) Valve Operation, Maintenance and\nInspection did not include a requirement to perform a visual inspection of the wellhead at least\nannually as required by API RP 1171 Section 9.3.2 (Section 9.3.2).\nSection 9.3.2 states in part that “…[t]he operator shall visually inspect each wellhead assembly at\nleast annually for leaks...\n”\nDuring the inspection, CalGEM requested PGE’s procedures addressing visual inspection of\nwellhead assemblies for leaks pursuant to Section 9.3.2. PGE provided CalGEM with its RIMP,\nSection 12, Wellhead (Christmas Tree) Valve Operation, Maintenance and Inspection, and Utility\nStandard: TD-4521S Gas Valve Maintenance Standard (Valve Standard). The Valve Standard\nspecified that PGE will “[i]nspect, operate, lubricate (if required)…=[g]as storage Christmas Tree\nwellhead valves once each calendar year, not to exceed 15 months. The standard did not specify\nany requirements for inspection of non-valve components or the wellhead itself for leaks. In\naddition, the procedures did not describe the process used to conduct a visual inspection of the\nwellhead assembly for leaks, or a process for what is to be done when a leak is discovered from a\nvisual inspection.\nTherefore, PGE’s written procedures for conducting operations, maintenance, and emergency\npreparedness and response activities were inadequate to ensure safe operation of a pipeline facility\nin accordance with § 192.12(c). PGE must revise its procedures to require and include adequate\ndetail for performing annual visual inspections of wellhead assemblies for leaks.\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).\n\n\n\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 Co maintain documentation of the safety\nimprovement 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 1-2022-062-NOA and, for\neach document you submit, please provide a copy in electronic format whenever possible. Smaller\nfiles may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive\naccompanied 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\n\n12022062NOA_Closure Letter_02022023_(21-231776)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nFebruary 2, 2023\nMs. Patti Poppe\nPresident and Chief Executive Officer\nPacific Gas & Electric Co\n3301 Crow Canyon Road\nSan Ramon, California 94583\nCPF 1-2022-062-NOA\nDear Ms. Poppe:\nOn November 8, 2021, through November 15, 2021, an inspector from 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 Pacific Gas & Electric Co’s procedures in Pleasant Creek, Mcdonald Island and Los\nMedanos Storage facilities in Yolo County, San Joaquin County, and Contra Costa County\n(respectively) California.. As a result of the inspection, Pacific Gas & Electric Co’s was issued a\nNotice of Amendment on August 18, 2022, with a request for further information on December\n22, 2022, which proposed amendment of your procedures.\nPacific Gas & Electric Co submitted its amended procedures on October 27, 2022 for the Notice\nAdmendement dated August 18, 2022, and responded to the Request for Further Amendement on\nJanuary 20, 2023 in response to the Request for Further Amendement dated December 22, 2022.\nMy staff reviewed the amended procedures, and it appears that the inadequacies outlined in this\nNotice of Amendment 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":15544}