{"operation":"document","citation":"CPF 12024030NOA","title":"PACIFIC GAS & ELECTRIC CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-04-23","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024030noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024030noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024030noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024030NOA","body":"Notice of Amendment involving PACIFIC GAS & ELECTRIC CO. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(2). The case was opened on 2024-04-23 and is reported as closed as of 2024-06-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024030NOA_Closure Letter_06112024_(23-265082).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024030NOA/12024030NOA_Closure%20Letter_06112024_(23-265082).pdf\n\n12024030NOA_Closure Letter_06112024_(23-265082)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024030NOA/12024030NOA_Closure%20Letter_06112024_(23-265082)_text.pdf\n\n12024030NOA_Notice of Amendment_04232024_(23-265082).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024030NOA/12024030NOA_Notice%20of%20Amendment_04232024_(23-265082).pdf\n\n12024030NOA_Notice of Amendment_04232024_(23-265082)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024030NOA/12024030NOA_Notice%20of%20Amendment_04232024_(23-265082)_text.pdf\n\n12024030NOA_Operator Response to Notice_05162024_(23-265082).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024030NOA/12024030NOA_Operator%20Response%20to%20Notice_05162024_(23-265082).pdf\n\n12024030NOA_Closure Letter_06112024_(23-265082)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJune 11, 2024\nMs. Patricia Poppe\nChief Executive Officer\nPacific Gas & Electric Company\n300 Lakeside Drive, 5th Floor\nOakland, California 94612\nCPF 1-2024-030-NOA\nDear Ms. Poppe:\nFrom June 5, 2023 to June 9, 2023, a State 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 Company’s (PGE) procedures for Los Medanos, McDonald\nIsland and Pleasant Creek Underground Natural Gas Storage Facilities (UNGSF) in Contra Costa,\nSan Joaquin, and Yolo counties, California, respectively. As a result of the inspection, PGE was\nissued a Notice of Amendment on April 23, 2024, which proposed amendment of your procedures.\nPGE submitted its amended procedures on May 16, 2024. 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\n\n\n\nCc: < Frances.Yee@pge.com>\n\n12024030NOA_Notice of Amendment_04232024_(23-265082)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nApril 23, 2024\nMs. Patricia Poppe\nChief Executive Officer\nPacific Gas & Electric Company\n300 Lakeside Drive, 5th Floor\nOakland, California 94612\nCPF 1-2024-030-NOA\nDear Ms. Poppe:\nFrom June 5, 2023 to June 9, 2023, a State 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 Company’s (PGE) procedures for Los Medanos, McDonald\nIsland and Pleasant Creek Underground Natural Gas Storage Facilities (UNGSF) in Contra Costa,\nSan Joaquin, and Yolo counties, California, respectively.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nPG&E’s plans or procedures. The items inspected and the inadequacies are described below:\n1. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs\n(1) ….\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see § 192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nPG&E’s written procedures for underground natural gas storage were inadequate to assure safe\n\n\n\noperation of a pipeline facility. Specifically, PG&E’s construction procedures required by\nAmerican Petroleum Institute Recommended Practice 1171 (2015) (API RP 1171), Section 11.2.1,\nfailed to adequately address API RP 1171, Section 6.2.3.\nSection 11.2.1 of API RP 1171 states, in part, “The operator shall develop and follow procedures\nfor the construction, operation, and maintenance of natural gas storage wells and reservoirs to\nestablish and maintain functional integrity.”\nSection 6.2.3 of API RP 1171 states, in part, “Wellhead equipment shall have operating pressure\nratings sufficient to exceed the maximum anticipated operating pressure.”\nDuring the inspection, PHMSA reviewed PG&E’s Wellhead Equipment Design Standard UGS-\nE1A-S. The process stated \"Wellhead equipment operating pressure ratings shall exceed maximum\nanticipated operating pressure [MAOP]\" but did not detail the MAOPs and pressure ratings for\ntheir assets or refer to the document that contained the information. PG&E also presented\nq05_multi-bowl_wellhead_design_whitepaper that included both the field MAOPs and field-\nspecific minimum pressure ratings for wellhead components but was not referred to by the\nprocedure.\nTherefore, PG&E’s construction procedures required by § 192.12(b)(2) and API RP 1171, Section\n11.2.1 were inadequate regarding the requirements of API RP 1171, Section 6.2.3. PG&E must\nrevise its procedures to address the deficiency outlined above.\n2. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs\n(1) ….\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see § 192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nPG&E’s written procedures for underground natural gas storage were inadequate to assure safe\noperation of a pipeline facility. Specifically, PG&E’s construction procedures required by API RP\n1171, Section 11.2.1, failed to adequately address API RP 1171, Section 6.7.3.\nSection 11.2.1 of API RP 1171 states, in part, “The operator shall develop and follow procedures\nfor the construction, operation, and maintenance of natural gas storage wells and reservoirs to\nestablish and maintain functional integrity.”\nSection 6.7.3 of API RP 1171 states, in part, “The operator shall repair a failed plug; the operator\nshall repair a well with any leak indication that may suggest a lack of isolation of the storage\nreservoir.”\n\n\n\nDuring the inspection, PHMSA reviewed PG&E’s UGS-E1D-S_Well Abandonment Standard and\nUGS-AG-S_Well Work Requirements_20220201. The procedure paraphrased API RP 1171,\nSection 6.7.3 but did not provide any detail of the plug repair or well repair process and did not\nrefer to the document that included the detailed process.\nTherefore, PG&E’s construction procedures required by § 192.12(b)(2) and API RP 1171, Section\n11.2.1 were inadequate regarding the requirements of API RP 1171, Section 6.7.3. PG&E must\nrevise its procedures to address the deficiency outlined above.\n3. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs\n(1) ….\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see § 192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nPG&E’s written procedures for underground natural gas storage were inadequate to assure safe\noperation of a pipeline facility. Specifically, PG&E’s construction procedures required by API RP\n1171, Section 11.2.1, failed to adequately address API RP 1171, Section 6.7.2.\nSection 11.2.1 of API RP 1171 states, in part, “The operator shall develop and follow procedures\nfor the construction, operation, and maintenance of natural gas storage wells and reservoirs to\nestablish and maintain functional integrity.”\nSection 6.7.2 of API RP 1171 states, in part, “The operator shall verify the presence and location\nof a cement plug after the plug is set and has reached a sufficient compressive strength; the operator\nshall correct deviations which may threaten isolation objectives of the plug.”\nDuring the inspection, PHMSA reviewed PG&E’s UGS-E1D-S_Well Abandonment Standard\nsection 3.5. The procedure paraphrases API RP 1171, Section 6.7.2 but did not include the process\nof how the location of the cement plug and how the sufficient compressive strength of the cement\nplug would be verified nor included a reference to a document that included the process.\nTherefore, PG&E’s construction procedures required by § 192.12(b)(2) and APR RP 1171, Section\n11.2.1 were inadequate regarding the requirements of API RP 1171, Section 6.7.2. PG&E must\nrevise its procedures to address the deficiency outlined above.\n4. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(1) ….\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\n\n\n\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see § 192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nPG&E’s written procedures for underground natural gas storage were inadequate to assure safe\noperation of a pipeline facility. Specifically, PG&E’s construction procedures required by API RP\n1171, Section 11.2.1, failed to adequately address API RP 1171, Section 6.7.2.\nSection 11.2.1 of API RP 1171 states in part, “The operator shall develop and follow procedures\nfor the construction, operation, and maintenance of natural gas storage wells and reservoirs to\nestablish and maintain functional integrity.”\nSection 6.7.2 of API RP 1171 states in part, “The operator shall use cement plugs (see 6.4.3) and/or\nmechanical plugs to isolate the storage zone from fluid migration. The use of hydrostatic pressure\nas a sole means of isolation shall not be acceptable.”\nDuring the inspection, PHMSA reviewed PG&E’s UGS-E1D-S_Well Abandonment Standard.\nThe procedure paraphrases API RP 1171, Section 6.7.2 but does not include detailed information\nof cement or mechanical plugs to be used or refer to the document that included the specific of the\nplugs to be used.\nTherefore, PG&E’s construction procedures required by § 192.12(b)(2) and API RP 1171, Section\n11.2.1 were inadequate regarding the requirements of API RP 1171, Section 6.7.2. PG&E must\nrevise its procedures to address the 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 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\n\n\n\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 PG&E 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-\n2024-030-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","truncated":false,"body_characters":13712}