# PACIFIC GAS & ELECTRIC CO — Notice of Amendment

- **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:** Not available
- **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.

Official case documents:

12022062NOA_Closure Letter_02022023_(21-231776).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022062NOA/12022062NOA_Closure%20Letter_02022023_(21-231776).pdf

12022062NOA_Closure Letter_02022023_(21-231776)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022062NOA/12022062NOA_Closure%20Letter_02022023_(21-231776)_text.pdf

12022062NOA_Notice of Amendment_08182022_(21-231776).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022062NOA/12022062NOA_Notice%20of%20Amendment_08182022_(21-231776).pdf

12022062NOA_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

12022062NOA_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

12022062NOA_Notice of Amendment_08182022_(21-231776)_text.pdf

NOTICE OF AMENDMENT
OVERNIGHT EXPRESS DELIVERY
August 18, 2022
Ms. Patti Poppe
President and Chief Executive Officer
Pacific Gas & Electric Co
3301 Crow Canyon Road
San Ramon, California 94583
CPF 1-2022-062-NOA
Dear Ms. Poppe:
From November 8, 2021, through November 15, 2021, an inspector from the California Geologic
Energy Management Division (CalGEM), acting as an agent for the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
inspected Pacific Gas & Electric Co’s (PGE) procedures for Pleasant Creek, McDonald Island and
Los Medanos Storage facilities in Yolo County, San Joaquin County, and Contra Costa County
(respectively) California.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
PGE’s plans or procedures, as described below:
1. § 192.12 Underground natural gas storage facilities.
(a) …
(c) Procedural manuals. Each operator of a UNGSF must prepare
and follow for each facility one or more manuals of written procedures
for conducting operations, maintenance, and emergency preparedness
and response activities under paragraphs (a) and (b) of this section.
Each operator must keep records necessary to administer such
procedures and review and update these manuals at intervals not
exceeding 15 months, but at least once each calendar year. Each
operator must keep the appropriate parts of these manuals accessible
at locations where UNGSF work is being performed. Each operator



must have written procedures in place before commencing
operations or beginning an activity not yet implemented.
PGE’s written procedures for conducting operations, maintenance, and emergency preparedness
and response activities (RIMP) were inadequate to ensure safe operation of a pipeline facility.
Specifically, PGE’s RIMP, Section 9 Mechanical Integrity of the Wells failed to describe in
sufficient detail the process for selecting an integrity assessment methodology and frequencies
when each methodology would be used as required by API RP 1171 Section 9.3.1 (Section 9.3.1).
Section 9.3.1 states in part that “[a]ctive well mechanical integrity evaluations shall include initial
and subsequent evaluations as determined using the risk assessment and the information derived
from the initial evaluation.”
At the time of the inspection, PGE’s written procedures for well integrity evaluation only listed
different types of potential integrity evaluations that PGE can perform but did not describe a
selection process and a frequency for each type of evaluation. The process should include criteria
for selection of evaluation, and frequencies for evaluations based on the risk assessments.
Therefore, PGE’s written procedures for conducting operations, maintenance, and emergency
preparedness and response activities were inadequate to ensure safe operation of a pipeline facility
in accordance with § 192.12(c). PGE must revise its procedures to include adequate detail for
selecting and implementing its various integrity assessment methodologies.
2. § 192.12 Underground natural gas storage facilities.
(a) …
(c) Procedural manuals. Each operator of a UNGSF must prepare
and follow for each facility one or more manuals of written procedures
for conducting operations, maintenance, and emergency preparedness
and response activities under paragraphs (a) and (b) of this section.
Each operator must keep records necessary to administer such
procedures and review and update these manuals at intervals not
exceeding 15 months, but at least once each calendar year. Each
operator must keep the appropriate parts of these manuals accessible
at locations where UNGSF work is being performed. Each operator
must have written procedures in place before commencing operations
or beginning an activity not yet implemented.
PGE’s written procedures for conducting operations, maintenance, and emergency preparedness
and response activities were inadequate to ensure safe operation of a pipeline facility. Specifically,
PGE’s Underground Storage Risk and Integrity Management Plan, RIMP Section 6, failed to
describe in sufficient detail each process PGE follows to maintain ongoing functional integrity of
its reservoirs as required by API RP 1171, Section 9.2.1 (Section 9.2.1).
Section 9.2.1 states in part,
“[t]he operator shall maintain functional integrity of storage wells and
reservoirs. Storage wells and reservoirs can have different characteristics resulting in unique
requirements in approaching integrity demonstration, verification, and monitoring.”



At the time of the inspection, PGE’s written procedures for functional integrity of the reservoirs
was inadequate because PGE failed to describe the integrity work in detail. The procedures
presented during the inspection only listed different integrity management processes used by PGE
to demonstrate functional integrity of the reservoirs but were not descriptive of the processes.
Therefore, PGE’s written procedures for conducting operations, maintenance, and emergency
preparedness and response activities were inadequate to ensure safe operation of a pipeline facility
in accordance with § 192.12(c). PGE must revise its procedures to include adequate detail
regarding its processes for maintaining ongoing functional integrity of its reservoirs.
3. § 192.12 Underground natural gas storage facilities.
(a) …
(c) Procedural manuals. Each operator of a UNGSF must prepare
and follow for each facility one or more manuals of written procedures
for conducting operations, maintenance, and emergency preparedness
and response activities under paragraphs (a) and (b) of this section.
Each operator must keep records necessary to administer such
procedures and review and update these manuals at intervals not
exceeding 15 months, but at least once each calendar year. Each
operator must keep the appropriate parts of these manuals accessible
at locations where UNGSF work is being performed. Each operator
must have written procedures in place before commencing operations
or beginning an activity not yet implemented.
PGE’s written procedures for conducting operations, maintenance, and emergency preparedness
and response activities were inadequate to ensure safe operation of a pipeline facility. Specifically,
PGE’s RIMP, Section 11 Safety Valve Operation, Maintenance and Inspection, did not include a
requirement to perform a physical inspection of a closed safety valve in order for it to be reopened,
in accordance with PGE’s practices in the field.
During the inspection, PGE provided CalGEM with procedures and question responses stating that
its storage well safety valves can be opened manually at the wellhead or from the control pad on
the well pad. The written procedures in place at the time of the inspection did not include a
requirement that an observer be present at the wellhead during safety valve re-opening in order to
inspect for abnormalities, which was identified by PGE to be its practice in the field.
Therefore, PGE’s written procedures for conducting operations, maintenance, and emergency
preparedness and response activities were inadequate to ensure safe operation of a pipeline facility
in accordance with § 192.12(c). PGE must revise its procedures to be consistent with their field
practices.
4. § 192.12 Underground natural gas storage facilities.
(a) …
(c) Procedural manuals. Each operator of a UNGSF must prepare
and follow for each facility one or more manuals of written procedures
for conducting operations, maintenance, and emergency preparedness



and response activities under paragraphs (a) and (b) of this section.
Each operator must keep records necessary to administer such
procedures and review and update these manuals at intervals not
exceeding 15 months, but at least once each calendar year. Each
operator must keep the appropriate parts of these manuals accessible
at locations where UNGSF work is being performed. Each operator
must have written procedures in place before commencing operations
or beginning an activity not yet implemented.
PGE’s written procedures for conducting operations, maintenance, and emergency preparedness
and response activities were inadequate to ensure safe operation of a pipeline facility. Specifically,
PGE’s RIMP, Section 12 Wellhead (Christmas Tree) Valve Operation, Maintenance and
Inspection did not include a requirement to perform a visual inspection of the wellhead at least
annually as required by API RP 1171 Section 9.3.2 (Section 9.3.2).
Section 9.3.2 states in part that “…[t]he operator shall visually inspect each wellhead assembly at
least annually for leaks...
”
During the inspection, CalGEM requested PGE’s procedures addressing visual inspection of
wellhead assemblies for leaks pursuant to Section 9.3.2. PGE provided CalGEM with its RIMP,
Section 12, Wellhead (Christmas Tree) Valve Operation, Maintenance and Inspection, and Utility
Standard: TD-4521S Gas Valve Maintenance Standard (Valve Standard). The Valve Standard
specified that PGE will “[i]nspect, operate, lubricate (if required)…=[g]as storage Christmas Tree
wellhead valves once each calendar year, not to exceed 15 months. The standard did not specify
any requirements for inspection of non-valve components or the wellhead itself for leaks. In
addition, the procedures did not describe the process used to conduct a visual inspection of the
wellhead assembly for leaks, or a process for what is to be done when a leak is discovered from a
visual inspection.
Therefore, PGE’s written procedures for conducting operations, maintenance, and emergency
preparedness and response activities were inadequate to ensure safe operation of a pipeline facility
in accordance with § 192.12(c). PGE must revise its procedures to require and include adequate
detail for performing annual visual inspections of wellhead assemblies for leaks.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement
Proceedings.
Please refer to this document and note the response options. Be advised that all material you
submit in response to this enforcement action is subject to being made publicly available. If you
believe that any portion of your responsive material qualifies for confidential treatment under 5
U.S.C. 552(b), along with the complete original document you must provide a second copy of the
document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment under
5 U.S.C. 552(b).



Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice
and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice
without further notice to you and to issue an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that Pacific Gas & Electric Co maintain documentation of the safety
improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of
plans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and
Hazardous Materials Safety Administration, 840 Bear Tavern Road, Suite 300, West Trenton, NJ
08628. In correspondence concerning this matter, please refer to CPF 1-2022-062-NOA and, for
each document you submit, please provide a copy in electronic format whenever possible. Smaller
files may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive
accompanied by the original paper copy to the Eastern Region Office.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings

12022062NOA_Closure Letter_02022023_(21-231776)_text.pdf

OVERNIGHT EXPRESS DELIVERY
February 2, 2023
Ms. Patti Poppe
President and Chief Executive Officer
Pacific Gas & Electric Co
3301 Crow Canyon Road
San Ramon, California 94583
CPF 1-2022-062-NOA
Dear Ms. Poppe:
On November 8, 2021, through November 15, 2021, an inspector from California Geologic Energy
Management Division (CalGEM), acting as an agent for the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)
inspected Pacific Gas & Electric Co’s procedures in Pleasant Creek, Mcdonald Island and Los
Medanos Storage facilities in Yolo County, San Joaquin County, and Contra Costa County
(respectively) California.. As a result of the inspection, Pacific Gas & Electric Co’s was issued a
Notice of Amendment on August 18, 2022, with a request for further information on December
22, 2022, which proposed amendment of your procedures.
Pacific Gas & Electric Co submitted its amended procedures on October 27, 2022 for the Notice
Admendement dated August 18, 2022, and responded to the Request for Further Amendement on
January 20, 2023 in response to the Request for Further Amendement dated December 22, 2022.
My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this
Notice of Amendment have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
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