CITY OF REDDING — Warning Letter

party submissionOfficial PDF520110004W_operator response_03222011.pdf#

520110004W_warning letter_01132011_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED January 13, 2011 Mr. Paul A. Cummings Assistant Director City of Redding Redding Electric Utility Gas Pipeline 17120 Clear Creek Road Redding, CA 96001 CPF 5-2011-0004W Dear Mr. Cummings: On March 16, 2010, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected manuals, records, and conducted a field audit of your pipeline facilities in Redding, California. As a result of the inspection, it appears that the City of Redding has committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable violation is:#

520110004W_warning letter_01132011_text.pdf, page 21. §192.605 Procedural manual for operations, maintenance, and emergencies. (b) Maintenance, and normal operations. (1) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and Subpart M of this part. Redding Electric Utility Gas Pipeline receives gas from Pacific Gas & Electric (PG&E) at a delivery station in Redding, California. At this location PG&E provides pressure control for the pipeline. However, the City of Redding does not have any records from PG&E regarding the required annual inspection of over pressure devices in accordance with 49 CFR, Part 192, Subpart M, §192.739(a). 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 Redding Electric Gas Pipeline 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 5-2011-0004W. 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 (#128469) 2#