{"operation":"document","citation":"CPF 12023057NOA","title":"PACIFIC GAS & ELECTRIC CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-11-09","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023057noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023057noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023057noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12023057NOA","body":"Notice of Amendment involving PACIFIC GAS & ELECTRIC CO. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(1). The case was opened on 2023-11-09 and is reported as closed as of 2023-12-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12023057NOA_Closure Letter_12122023_(22-235006).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023057NOA/12023057NOA_Closure%20Letter_12122023_(22-235006).pdf\n\n12023057NOA_Closure Letter_12122023_(22-235006)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023057NOA/12023057NOA_Closure%20Letter_12122023_(22-235006)_text.pdf\n\n12023057NOA_Notice of Amendment_11092023_(22-235006).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023057NOA/12023057NOA_Notice%20of%20Amendment_11092023_(22-235006).pdf\n\n12023057NOA_Notice of Amendment_11092023_(22-235006)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023057NOA/12023057NOA_Notice%20of%20Amendment_11092023_(22-235006)_text.pdf\n\n12023057NOA_Operator Response to Notice_12062023_(22-235006).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023057NOA/12023057NOA_Operator%20Response%20to%20Notice_12062023_(22-235006).pdf\n\n12023057NOA_Notice of Amendment_11092023_(22-235006)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nNovember 9, 2023\nMr. Joe Forline\nSenior Vice President, Gas Operations\nPacific Gas & Electric Co\n6121 Bollinger Canyon Rd 3450d\nSan Ramon, California 94583\nCPF 1-2023-057-NOA\nDear Mr. Forline:\nFrom June 27, 2022 to July 1, 2022, 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 Pacific Gas & Electric Co’s (PGE) procedures for Los Medanos, McDonald Island and\nPleasant Creek depleted hydrocarbon Underground Natural Gas Storage Facilities (UNGSF) in\nContra Costa, San Joaquin and Yolo counties, California, respectively.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within PGE’s\nplans or procedures. The items inspected and the inadequacies are described below:\n1. 49 C.F.R. § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs\n(1) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed after\nJuly 18, 2017, must meet all provisions of API RP 1171 (incorporated\nby reference, see § 192.7), and paragraphs (c) and (d) of this section,\nprior to commencing operations.\nPGE’s construction procedures required by § 192.12(b)(1) were inadequate. Specifically, PGE’s\nTubular Equipment Design Standard, Utility Standard: UGS-E1B-S, Rev 0 and its Cementing\n\n\n\nStandard, Utility Standard: UGS-EC1-S, Rev 0 failed to satisfy API RP 1171 Sections 11.2.1\n(Section 11.2.1) and 6.3.5 (Section 6.3.5).\nSection 11.2.1 states in part “The operator shall develop and follow procedures for the\nconstruction, operation, and maintenance of natural gas storage wells and reservoirs to establish\nand maintain functional integrity.”\nCorrespondingly, as to those procedures governing the construction, operation, and maintenance\nof PGE’s UNGSF, Section 6.3.5 states in part, “The production casing shall be free of open\nperforations or holes other than the planned completion interval(s). Perforations created for\ninvestigative or remedial work shall be sealed to establish hydraulic isolation.”\nDuring the inspection, CalGEM reviewed PGE’s construction standards relative to Section 6.3.5,\nwhich included its Tubular Equipment Design Standard (UGS – E1B – S) and its Cementing\nStandard (UGS – E1C – S). These standards failed to mandate that its production casing be free\nof open perforations or holes other than the planned completion intervals. The standards also failed\nto mandate that perforations created for investigative or remedial work shall be sealed to establish\nhydraulic isolation (e.g. Section 3.6 of the Cementing Standard). The Cementing Standard used\ndiscretionary “should” statements instead of including the mandatory “shall” requirements under\nSection 6.3.5.\nTherefore, PGE’s written procedures required by §192.12(b)(1) pursuant to meeting the provisions\nof Sections 11.2 1 and 6.3.5 were inadequate. PGE must revise its procedures to address the\ndeficiency outlined above.\n2. § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs\n(1) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed after\nJuly 18, 2017, must meet all provisions of API RP 1171 (incorporated\nby reference, see § 192.7), and paragraphs (c) and (d) of this section,\nprior to commencing operations.\nPGE’s construction procedures required by § 192.12(b)(1) were inadequate. Specifically, PGE’s\nWellhead Equipment Design Standard, Utility Standard: UGS-E1A-S, Section 2.3 (Wellhead\nDesign Standard) failed to satisfy API RP 1171 Sections 11.2.1 (Section 11.2.1) and 6.2.3 (Section\n6.2.3).\nSection 11.2.1 states in part “The operator shall develop and follow procedures for the\nconstruction, operation, and maintenance of natural gas storage wells and reservoirs to establish\nand maintain functional integrity.”\nCorrespondingly, as to those procedures governing the construction, operation, and maintenance\nof PGE’s UNGSF, Section 6.2.3 states in part, “Wellhead equipment shall have operating pressure\nratings sufficient to exceed the maximum anticipated operating pressure.”\n\n\n\n3. During the inspection, PGE’s Wellhead Design Standard Section 2.3 was reviewed. The procedure\ndid not specify the maximum anticipated operating pressure of each field nor what the required\nrating for each wellhead component must be to meet the standard of Section 6.2.3.\nTherefore, PGE’s written procedures required by § 192.12(b)(1) pursuant to meeting the\nprovisions of Sections 11.2 and 6.2.3 were inadequate. PGE must revise its procedures to address\nthe deficiency outlined above.\n§ 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs\n(1) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed after\nJuly 18, 2017, must meet all provisions of API RP 1171 (incorporated\nby reference, see § 192.7), and paragraphs (c) and (d) of this section,\nprior to commencing operations.\nPGE’s construction procedures required by § 192.12(b)(1) were inadequate. Specifically, PGE’s\nUtility Standard UGS-E1D-S, Well Abandonment Standard, failed to satisfy API RP 1171 Sections\n11.2.1 (Section 11.2.1) and 6.7.2 (Section 6.7.2).\nSection 11.2.1 states in part “The operator shall develop and follow procedures for the\nconstruction, operation, and maintenance of natural gas storage wells and reservoirs to establish\nand maintain functional integrity.”\nCorrespondingly, as to those procedures governing the construction, operation, and maintenance\nof PGE’s UNGSF, Section 6.7.2 states in part “The operator shall determine the location of\ngroundwater and hydrocarbon bearing zones (in addition to the storage zone) penetrated by the\nwell to be abandoned, and the condition of the well's casing and cement across those zones, to\nprevent communication between any of those zones during and after plugging of the well.”\nDuring the inspection, CalGEM reviewed PGE’s Well Abandonment Standard (UGS-E1D-S). This\nstandard, at section 3.2 of UGS-EID-S), generally parallels the quoted language from Section 6.7.2\nabove, and fails to establish or refer to any process or procedure or evaluation regarding how the\ncondition of a well’s casing and cement across a zone shall be determined (or addressing\nevaluation/determination of the location of groundwater and hydrocarbon bearing zones to prevent\ncommunication during abandonment operations.\nTherefore, PGE’s written procedures required by § 192.12(b)(1) pursuant to meeting the\nprovisions of Sections 11.2 and 6.7.2 were inadequate. PGE must revise its procedures to address\nthe deficiency outlined above.\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 Compliance\nProceedings.\n\n\n\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\naction will be closed.\nIt is requested (not mandated) that PGE maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Robert Burrough, Director, Eastern Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF 1-\n2023-057-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n\n12023057NOA_Closure Letter_12122023_(22-235006)_text.pdf\n\nVIA ELECTRONIC MAIL TO: J9FL@pge.com\nDecember 12, 2023\nMr. Joe Forline\nSenior Vice President, Gas Operations\nPacific Gas & Electric Co\n6121 Bollinger Canyon Rd 3450d\nSan Ramon, California 94583\nCPF 1-2023-057-NOA\nDear Mr. Forline:\nFrom June 27, 2022 to July 1, 2022, 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 Pacific Gas & Electric Co’s (PGE) procedures for Los Medanos, McDonald Island and\nPleasant Creek depleted hydrocarbon Underground Natural Gas Storage Facilities (UNGSF) in\nContra Costa, San Joaquin and Yolo counties, California, respectively. As a result of the\ninspection, Pacific Gas & Electric Co was issued a Notice of Amendment on November 9, 2023.\nPacific Gas & Electric Co submitted its amended procedures on December 6, 2023. 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":12093}