# BULLDOG GAS & POWER LLC — Warning Letter

- **operation:** document
- **citation:** CPF 520090029W
- **title:** BULLDOG GAS & POWER LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2009-11-16
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.805(b).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520090029w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520090029w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520090029w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520090029W
**body:**

Warning Letter involving BULLDOG GAS & POWER LLC. PHMSA's enforcement data identifies the cited regulation as 192.805(b). The case was opened on 2009-11-16 and is reported as closed as of 2009-11-16. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520090029W_warning letter_11162009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520090029W/520090029W_warning%20letter_11162009.pdf

520090029W_warning letter_11162009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520090029W/520090029W_warning%20letter_11162009_text.pdf

520090029W_warning letter_11162009_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 16, 2009
Mr. Chris Charrette
Plant Manager
Bulldog Gas & Power, LLC
950 Waterbird Way
Martinez, CA 94553
CPF 5-2009-0029W
Dear Mr. Charrette:
On March 23, 2009, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
pipeline safety Operator Qualification (OQ) Program in Martinez, California.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and
the probable violation is:
1. § 192.805 Operator Qualification program.
(b) Ensure through evaluation that individuals performing covered tasks are
qualified;
The Bulldog Gas & Power OQ program describes policy and criteria for the use of
training for individuals performing covered tasks for its pipeline system, but does not
describe criteria for re-training and re-evaluation if qualifications are questioned. In
addition, the program indicates two-year intervals for re-evaluation, but it does not
technically justify this requirement.



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 item(s)
identified in this letter. Failure to do so will result in Bulldog Gas & Power, LLC 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 5-2009-0029W. 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).
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 P. Nguyen (#123246)
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