BULLDOG GAS & POWER LLC — Warning Letter

520080020w_warning letter_09052008_text.pdf, page 1Official PDFpz' of Cofgies l l k. , e. U 5. Department of Transportation Plpelllne and HozmdoLts Mdterlolls Safety Admlnmstrdtlon 12300 W Dakota Ave, Suite 110 Lakewood, CO 80228 WA~IXG KKTTKR September 5, 2008 Mr. Nicholas Farros Manager Bulldog Gas and Power P O. Box 2362 Martinez, CA 84553 CPF 5-2008-0020M Dear Mr. Fanos On March 11-12, 2008, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your gas transmission system m Martinez, California As a result of the inspection, it appears that you have committed probable violations of the Pipehne Safety Regulations, Title 49, Code of Federal Regulations The items inspected and the probable violations are (192. 605 Procedural Manual for operations, maintenance, and emei gencies. (b) Maintenance and normal operations The manual required by paragraph (a) of this sectjlon must include procedures for the following, if applicable, to provide safety during maintenance and operations. (1) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and subpart M of this part. (2) Controlling corrosion in accordance with the operations and maintenance requirements of subpart Y of this part.#

520080020w_warning letter_09052008_text.pdf, page 2(3) Making construction records, maps, and operating history available to appropriate operating personnel. (4) Gathering of data needed for repox ting incidents undex Part 791 of this chapter in a timely and effective manner. (5) Starting up and shutting down any part of the pipehne in a manner designed to assuage operation within the MAOP hmits prescribed by this part, plus the build-up allowed for operation of pressure-Hmitiing and control devices. (6) Maintaining compressor stations, including provisions for isolating units oi sections of pipe and fox' purging befoxe returning to service. (7) Stating, operating axxd shutting down gas compxessor units. (8) Periodically reviewing the work done by operator personnel to determine the effectiveness and adequacy of the pxocedures used in normal opexation and maintenance and modifying the procedures when deficiencies are found. (9) I'aking adequate precautions in excavated txenches to protect personnel from the hazards of unsafe accumulations of vapor or gas, and making available when needed at the excavation, emergency rescue equipment, including a breathing apparatus and a rescue harness and line. The operator's procedural manual for operations, maintenance, and emergency response did not include provisions for meeting the reporting requirements of Part 191, reviewing and updating procedures contained in the plan on an annual basis, making construction records, maps and operating history available to appropriate operating personnel, periodically reviewing the work down by operator's personnel to determine the effectiveness and adequacy of procedures, a damage prevention program (except for the one-call system procedures), MAOP procedures, purging procedures, procedures for ~oining of plastic pipe, and corrosion control procedures (as apphcable) Z. $192. 605 Procedural Manual for operations, maintenance, and emergencies. (c) Abnormal Operation For transmission hnes, the manual required by paragraph (a) of this section must include procedures for the foHowiing to provide safety when operating design hxnits have been exceeded: (I) Responding to, investigating, and correcting the cause of: (i) Unintended closure of valves or shutdowns; (ii) Increase or decrease in pressure or flow rate outside normal operating limits; (iii) I. oss of communications; (iv) Operation of any safety device; (v) An other foreseeable malfunction of a component, deviation from normal operation, or personnel error, which may result in a hazard to persons or property. (2) Checking variations from normal operation after abnormal operation has ended at sufficient critical locations in the system to determine continued integrity and safe operation. (3) Notifying xesponsible operator personnel when notice of an abnormal operation is i eceived.#

520080020w_warning letter_09052008_text.pdf, page 3The procedural manual did not contain any reference to abnormal operations (e) Surveillance, emergency response, and accidentinvestigation. The procedures required by )$192. 613(a), 192. 615, and 192. 617 must be included in the manual required by paragraph (a) of this section. The procedural manual did not contain procedures for detecting and responding to changes in Class Location and there was no pipehne-specific emergency plan Some of the necessary elements of an emergency plan were contained in a general facihty response plan No records pertaining to customer notification were available during the inspection $192. 731(a) Compressor stations: Inspection and testing of rehef' devices. (a) Except for rupture discs, each pressure reHeving device in a compressor station must be inspected and testing in accordance with g(192. 739 and 192. 743, and must be operated periodicaHy to determine that it opens at the correct set pressure. No documentation of compressor station rehef device testing was available during the inspection Under 49 United States Code, ) 60122, you are subject to a civil penalty not to exceed $100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000 for any related series of violations We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time We advise you to correct the items identified in this letter#

520080020w_warning letter_09052008_text.pdf, page 4Failure to do so will result m Bulldog Gas and Power being subject to additional enforcement action No reply to this letter is required If you choose to reply, in your correspondence please refer to CPF 5-ZOO8-OOZOW. Be advised that all material you submit in response to this enforcement action is subject to being made pubhcly available. If you beheve that any portion of your responsive material qualifies for confidential treatment under 5 U S C 552(b), along with the complete orignial document you must provide a second copy of the document with the potions you believe quahfy for confidential treatment redacted and an explanation of why you beheve the redacted infoiTnation quahfies for confidential treatment under 5 U. S C 552(b) Sincerely, ~7 Chris Hoidal Director, Western Region Pipehne and Hazardous Materials Safety Administration cc PHP-60 Comphance Registry PHP-500 J. Stahoviak (0120711)#