{"operation":"document","citation":"CPF 520080020W","title":"BULLDOG GAS & POWER LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-09-05","effective_on":null,"summary":"CLOSED warning letter citing 192.16(d), 192.605(b), 192.605(c), 192.605(e), 192.731(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080020w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080020w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080020w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520080020W","body":"Warning Letter involving BULLDOG GAS & POWER LLC. PHMSA's enforcement data identifies the cited regulations as 192.16(d),  192.605(b),  192.605(c),  192.605(e),  192.731(a). The case was opened on 2008-09-05 and is reported as closed as of 2008-09-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520080020W_warning letter_09052008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080020W/520080020W_warning%20letter_09052008.pdf\n\n520080020w_warning letter_09052008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080020W/520080020w_warning%20letter_09052008_text.pdf\n\n520080020w_warning letter_09052008_text.pdf\n\npz' of Cofgies l l k. , e.\nU 5. Department\nof Transportation\nPlpelllne and\nHozmdoLts Mdterlolls Safety\nAdmlnmstrdtlon\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nWA~IXG KKTTKR\nSeptember 5, 2008\nMr. Nicholas Farros\nManager\nBulldog Gas and Power\nP O. Box 2362\nMartinez, CA 84553\nCPF 5-2008-0020M\nDear Mr. Fanos\nOn March 11-12, 2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\ngas transmission system m Martinez, California\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipehne Safety Regulations, Title 49, Code of Federal Regulations The items inspected and the\nprobable violations are\n(192. 605 Procedural Manual for operations, maintenance, and emei gencies.\n(b) Maintenance and normal operations The manual required by paragraph (a) of\nthis sectjlon must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of\nthe requirements of this subpart and subpart M of this part.\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of subpart Y of this part.\n\n\n\n(3) Making construction records, maps, and operating history available to\nappropriate operating personnel.\n(4) Gathering of data needed for repox ting incidents undex Part 791 of this chapter\nin a timely and effective manner.\n(5) Starting up and shutting down any part of the pipehne in a manner designed to\nassuage operation within the MAOP hmits prescribed by this part, plus the build-up\nallowed for operation of pressure-Hmitiing and control devices.\n(6) Maintaining compressor stations, including provisions for isolating units oi\nsections of pipe and fox' purging befoxe returning to service.\n(7) Stating, operating axxd shutting down gas compxessor units.\n(8) Periodically reviewing the work done by operator personnel to determine the\neffectiveness and adequacy of the pxocedures used in normal opexation and\nmaintenance and modifying the procedures when deficiencies are found.\n(9) I'aking adequate precautions in excavated txenches to protect personnel from\nthe hazards of unsafe accumulations of vapor or gas, and making available when\nneeded at the excavation, emergency rescue equipment, including a breathing\napparatus and a rescue harness and line.\nThe operator's procedural manual for operations, maintenance, and emergency response\ndid not include provisions for meeting the reporting requirements of Part 191, reviewing\nand updating procedures contained in the plan on an annual basis, making construction\nrecords, maps and operating history available to appropriate operating personnel,\nperiodically reviewing the work down by operator's personnel to determine the\neffectiveness and adequacy of procedures, a damage prevention program (except for the\none-call system procedures), MAOP procedures, purging procedures, procedures for\n~oining of plastic pipe, and corrosion control procedures (as apphcable)\nZ. $192. 605 Procedural Manual for operations, maintenance, and emergencies.\n(c) Abnormal Operation For transmission hnes, the manual required by paragraph\n(a) of this section must include procedures for the foHowiing to provide safety when\noperating design hxnits have been exceeded:\n(I) Responding to, investigating, and correcting the cause of:\n(i) Unintended closure of valves or shutdowns;\n(ii) Increase or decrease in pressure or flow rate outside normal operating limits;\n(iii) I. oss of communications;\n(iv) Operation of any safety device;\n(v) An other foreseeable malfunction of a component, deviation from normal\noperation, or personnel error, which may result in a hazard to persons or property.\n(2) Checking variations from normal operation after abnormal operation has\nended at sufficient critical locations in the system to determine continued integrity\nand safe operation.\n(3) Notifying xesponsible operator personnel when notice of an abnormal operation\nis i eceived.\n\n\n\nThe procedural manual did not contain any reference to abnormal operations\n(e) Surveillance, emergency response, and accidentinvestigation. The procedures\nrequired by )$192. 613(a), 192. 615, and 192. 617 must be included in the manual\nrequired by paragraph (a) of this section.\nThe procedural manual did not contain procedures for detecting and responding to\nchanges in Class Location and there was no pipehne-specific emergency plan Some of\nthe necessary elements of an emergency plan were contained in a general facihty\nresponse plan\nNo records pertaining to customer notification were available during the inspection\n$192. 731(a) Compressor stations: Inspection and testing of rehef' devices.\n(a) Except for rupture discs, each pressure reHeving device in a compressor station\nmust be inspected and testing in accordance with g(192. 739 and 192. 743, and must\nbe operated periodicaHy to determine that it opens at the correct set pressure.\nNo documentation of compressor station rehef device testing was available during the\ninspection\nUnder 49 United States Code, ) 60122, you are subject to a civil penalty not to exceed $100, 000\nfor each violation for each day the violation persists up to a maximum of $1, 000, 000 for any\nrelated series of violations We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time We advise you to correct the items identified in this letter\n\n\n\nFailure to do so will result m Bulldog Gas and Power being subject to additional enforcement\naction\nNo reply to this letter is required If you choose to reply, in your correspondence please refer to\nCPF 5-ZOO8-OOZOW. Be advised that all material you submit in response to this enforcement\naction is subject to being made pubhcly available. If you beheve that any portion of your\nresponsive material qualifies for confidential treatment under 5 U S C 552(b), along with the\ncomplete orignial document you must provide a second copy of the document with the potions\nyou believe quahfy for confidential treatment redacted and an explanation of why you beheve\nthe redacted infoiTnation quahfies for confidential treatment under 5 U. S C 552(b)\nSincerely, ~7\nChris Hoidal\nDirector, Western Region\nPipehne and Hazardous Materials Safety Administration\ncc PHP-60 Comphance Registry\nPHP-500 J. Stahoviak (0120711)","truncated":false,"body_characters":7227}