{"operation":"document","citation":"CPF 520100014W","title":"SILICON VALLEY POWER — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-08-04","effective_on":null,"summary":"CLOSED warning letter citing 192.161, 192.605(a), 192.605(c), 192.731(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100014w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100014w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100014w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520100014W","body":"Warning Letter involving SILICON VALLEY POWER. PHMSA's enforcement data identifies the cited regulations as 192.161,  192.605(a),  192.605(c),  192.731(c). The case was opened on 2010-08-04 and is reported as closed as of 2010-08-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520100014W_warning letter_08042010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100014W/520100014W_warning%20letter_08042010.pdf\n\n520100014W_warning letter_08042010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100014W/520100014W_warning%20letter_08042010_text.pdf\n\n520100014W_warning letter_08042010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 4, 2010\nMr. John Roukema\nDirector Electric Utility\nSilicon Valley Power, City of Santa Clara\n1500 Warburton Avenue\nSanta Clara, CA 95050\nCPF 5-2010-0014W\nDear Mr. Roukema:\nOn January 19-22 and February 24-26, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected your written procedures contained within your Operations and Maintenance (O&M)\nProcedural Manuals for the Raesfeld gas system. Our representatives also reviewed records to\nensure that the O&M procedures were properly implemented. These procedures and records\nreview were conducted at your Santa Clara, California office.\nAs a result of the inspection, it appears that Silicon Valley Power (SVP) has committed\nprobable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations.\nThe items inspected and the probable violations are:\n1. §192.161 Supports and Anchors\n(a) Each pipeline and its associated equipment must have enough anchors or\nsupports to:\n(1) Prevent undue strain on connected equipment;\n\n\n\n(2) Resist longitudinal forces caused by a bend or offset in the pipe; and,\n(3) Prevent or damp out excessive vibration.\n(b) Each exposed pipeline must have enough supports or anchors to protect the\nexposed pipe joints from the maximum end force caused by internal pressure and\nany additional forces caused by temperature expansion or contraction or by the\nweight of the pipe and its contents.\n(c) Each support or anchor on an exposed pipeline must be made of durable,\nnoncombustible material and must be designed and installed as follows:\n(1) Free expansion and contraction of the pipeline between supports or anchors\nmay not be restricted.\n(2) Provision must be made for the service conditions involved.\n(3) Movement of the pipeline may not cause disengagement of the support\nequipment.\n(d) Each support on an exposed pipeline operated at a stress level of 50 percent or\nmore of SMYS must comply with the following:\n(1) A structural support may not be welded directly to the pipe.\n(2) The support must be provided by a member that completely encircles the\npipe.\n(3) If an encircling member is welded to a pipe, the weld must be continuous and\ncover the entire circumference.\nSilicon Valley Power (SVP) has installed a 12-inch valve next to PG&E metering station and\nnew pressure relief at the end of its 12-inch pipeline segment. This valve and newly installed\nrelief device are heavy and appear to be inadequately supported. Each pipeline and its\nassociated equipment must have enough anchors or support to prevent undue strain on\nconnected equipment, resist longitudinal forces, and prevent or damp out excessive vibration.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual\nof written procedures for conducting operations and maintenance activities and\nfor emergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed\nand updated by the operator at intervals not exceeding 15 months, but at least one\neach calendar year. This manual must be prepared before operations of a\npipeline system commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\n\n\n\nSVP removed the automatic blow-down system for the compressors and replaced it with a\nmanual blow-down system at the compressor station. This modification did not follow the\nManagement of Change (MOC) procedures detailed in the SVP Operations and Maintenance\nManual. Specifically, the MOC procedures for evaluating and implementing the modification\nwere not utilized by the responsible SVP personnel. Also, the communications regarding the\nmodifications to the individuals performing the tasks were done verbally and not documented\nwhich did not follow the MOC procedures.\n3. §192.605 Procedural manual for operations, maintenance, and emergencies\n(c) Abnormal operation. For transmission lines, the manual required by\nparagraph (a) of this section must include procedures for the following to provide\nsafety when operating design limits have been exceeded:\n(4) Periodically reviewing the response of operator personnel to determine the\neffectiveness of the procedures controlling abnormal operation and taking\ncorrective action where deficiencies are found.\nSVP experienced three (3) abnormal operating conditions on March 10, 2008, June 29, 2009,\nand July 2, 2009. SVP responded in timely manner correcting the conditions. However, SVP\nfailed to review the response by its personnel to the abnormal operating condition to determine\nthe effectiveness of the procedures controlling abnormal operations and taking corrective\naction where deficiencies are found. Following each abnormal operating condition, the related\nO&M procedures need to be reviewed to determine that the personnel actions utilizing that\nprocedure are effective.\n4. §192.731 Compressor stations: Inspection and testing of relief devices.\n(c) Each remote control shutdown device must be inspected and tested at\nintervals not exceeding 15 months, but at least once each calendar year, to\ndetermine that it functions properly.\nSVP did not inspect the all of the compressor safety devices. All compressor data transmitters\nthat are functioning as safety devices such as suction pressure, discharge pressure, discharge\ntemperature, oil temperature, oil pressure, compressor vibration and motor vibration need to be\ninspected and tested at intervals not exceeding 15 months, but at least once each calendar year,\nto determine that they are functioning properly.\n\n\n\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the items\nidentified in this letter. Failure to do so will result in Silicon Valley Power being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2010-0014W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 H. Monfared (#128425)","truncated":false,"body_characters":7867}