{"operation":"document","citation":"CPF 520120004S","title":"CITY OF VERNON — Safety Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-03-06","effective_on":null,"summary":"CLOSED safety order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520120004s.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520120004s.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520120004s","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520120004S","body":"Safety Order involving CITY OF VERNON. The dataset does not identify a cited regulation for this case. The case was opened on 2012-03-06 and is reported as closed as of 2013-08-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520120004S_closure letter_08062013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520120004S/520120004S_closure%20letter_08062013.pdf\n\n520120004S_closure letter_08062013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520120004S/520120004S_closure%20letter_08062013_text.pdf\n\n520120004S_NOPSO_03062012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520120004S/520120004S_NOPSO_03062012.pdf\n\n520120004S_NOPSO_03062012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520120004S/520120004S_NOPSO_03062012_text.pdf\n\n520120004S_Safety Order_05302012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520120004S/520120004S_Safety%20Order_05302012.pdf\n\n520120004S_Safety Order_05302012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520120004S/520120004S_Safety%20Order_05302012_text.pdf\n\n520120004S_Safety Order_05302012_text.pdf\n\nMAY 30 2012\nMr. Carlos R. Fandino, Jr.\nDirector, Light & Power Department\nCity of Vernon\n4305 Santa Fe Avenue\nVernon, CA 90058\nRe: CPF No. 5-2012-0004S\nDear Mr. Fandino:\nEnclosed please find the Safety Order issued in the above-referenced case. It makes a finding\nthat the City of Vernon’s intrastate natural gas transmission pipeline has a condition or\nconditions that pose a pipeline integrity risk and specifies actions that must be taken by the City\nto ensure that the public, property, and the environment are protected from the risk. When the\nterms of the order have been completed, as determined by the Director, Western Region, this\nenforcement action will be closed. Service of the Safety Order by certified mail is deemed\neffective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Mark Whitworth, City Administrator, City of Vernon\nMr. Chris Hoidal, Director, Western Region, OPS\nMr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nCity of Vernon, California, ) CPF No. 5-2012-0004S\na municipal corporation, )\n)\n)\n)\nRespondent. )\n____________________________________)\nSAFETY ORDER\nPursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), conducted an investigation of the safety of the City\nof Vernon, California’s (City or Respondent) intrastate natural gas transmission pipeline. The\nline runs completely within the City of Vernon in Los Angeles County, California.\nAs a result of the investigation, the Director, Western Region, OPS (Director), issued to\nRespondent, by letter dated March 6, 2012, a Notice of Proposed Safety Order (Notice). In\naccordance with 49 C.F.R. § 190.239, the Notice proposed finding that conditions existed on the\nCity’s pipeline system that posed a pipeline integrity risk to public safety, property or the\nenvironment, and proposed that Respondent take certain measures to ensure that the public,\nproperty, and the environment were protected from such risk.\nThe City responded to the Notice by letter dated March 21, 2012. In its letter, Respondent\nexpressed its intent to comply with the terms of the Notice, as proposed, thereby authorizing the\nentry of this Safety Order. Respondent did not request a hearing, and therefore has waived its\nright to one.\nFindings of Pipeline Integrity Risk\nRespondent does not contest the proposed findings in the Notice that its intrastate natural gas\ntransmission pipeline has a condition or conditions that pose a pipeline integrity risk.\nAccordingly, pursuant to 49 U.S.C. § 60117(l) and 49 C.F.R. § 190.239, I find as follows:\n• The City operates an intrastate natural gas transmission pipeline entirely within the City\nof Vernon in Los Angeles County, California. The 7.3-mile line is 10.75 inches in\ndiameter, with a wall thickness of 0.365 inches, and was constructed between 1997-2000\n(the Pipeline). The Pipeline includes a lateral that serves the Malburg Generating Station.\n\n\n\n2\nThis section was constructed between 2002 and 2004. The Pipeline is connected to\nSouthern California Gas Company’s (SoCal) Line 765.\nunder major city streets and through a highly industrialized area. The Pipeline also\n• The entire Pipeline is located in a populated High Consequence Area (HCA),1 running\ncrosses over the Los Angeles River.\n• The maximum allowable operating pressure (MAOP) of the Pipeline, prior to the\nissuance of the Notice of Proposed Safety Order, was 650 psig but the City confirmed\nthat the typical operating pressure is between 300-400 psig. Pressure control and over-\npressure protection is provided by SoCal and is not under the direct control of the City.\n• The Pipeline was last hydrotested seven years ago, on March 30, 2005. Prior to 2005, the\nPipeline was idle. No other integrity assessment has occurred since that time.\n• The City previously proposed using external corrosion direct assessment (ECDA) to\ninspect the integrity of the Pipeline. On January 31, 2012, the City informed the Director\nof its intent to make the line “piggable” and switch to an in-line inspection (ILI) tool to\nconduct an integrity assessment of the line. The City proposed to inspect the 960-foot\nlateral to the Malburg Generating Station with guided-wave ultrasonic technology. The\nCity has elected to switch methods due to cost and logistical concerns. Due to the change\nin reassessment technologies, the March 30, 2012 reassessment deadline would not be\nachievable and the City of Vernon sought approval for both the assessment technology\nchange and the extension of the assessment interval deadline.\n• After further review, PHMSA issued the Notice. While the Pipeline passed a hydrotest in\n2005, little else is known about any “time dependent” integrity threats such as corrosion\nor third-party damage that may have compromised the integrity of the Pipeline since\n2005.\n• The City further proposes to take 3.1 miles of the Pipeline out of service, pressurize it\nwith nitrogen, and cathodically protect it from corrosion. The remaining length of active\nline will be approximately 4.2 miles.\nIssuance of Safety Order\nSection 60117(l) of Title 49, United States Code, provides for the issuance of a safety order, after\nreasonable notice and the opportunity for a hearing, requiring corrective measures, which may\ninclude physical inspection, testing, repair, or other action, as appropriate. The basis for making\nthe determination that a pipeline facility has a condition or conditions that pose a pipeline\nintegrity risk to public safety, property, or the environment is set forth both in the above-\nreferenced statute and 49 C.F.R. §190.239.\n1 “High Consequence Areas” are defined in 49 C.F.R. § 192.903.\n\n\n\n3\nAfter evaluating the foregoing findings and considering the unknown integrity of the Pipeline, its\nlocation in an HCA, and the likelihood that the conditions could worsen or develop on other\nareas of the Pipeline and potentially impact its serviceability, PHMSA finds that Respondent’s\nintrastate natural gas pipeline has a condition or conditions that pose a pipeline integrity risk to\npublic safety, property, or the environment. Accordingly, PHMSA issues this Safety Order,\nwhich requires that Respondent take certain measures specified below to address the risk.\nCorrective Measures\nPursuant to 49 U.S.C. § 60117(l) and 49 C.F.R. § 190.239, the City must take the following\nremedial requirements with respect to the Pipeline:\n1. Leak Surveys. Conduct monthly leak surveys on the Pipeline.\n2. Maximum Allowable Operating Pressure Reduction. Reduce the Maximum Allowable\nOperating Pressure (MAOP) on the Pipeline by 20 percent so that it does not exceed 520\npsig. This pressure restriction will remain in effect until the City receives from the\nDirector, written approval to increase or restore the former pressure. The Director may\nallow the removal or modification of the pressure restriction, upon a written request from\nRespondent demonstrating that increasing the pressure or returning the line to its original\nMAOP would be justified based on a reliable engineering analysis. This analysis must\nshow that the proposed pressure increase would be safe, considering all known defects\n(either repaired or remaining), and must include all anomalies, the outcome of girth weld\nevaluations, and the operating parameters of the Pipeline.\n3. Expedite Removal of 3.1 miles from Service: Complete isolation of the 3.1-mile segment\nof the line to be removed from service and pressurize the line with nitrogen. If the line is\nto be considered for return to service, it must comply with all applicable regulations in 49\nC.F.R. Part 192, including maintenance of cathodic protection levels.\n4. ILI Results. Upon completion of a successful ILI tool run, the City must submit to the\nDirector a preliminary report outlining any anomaly indications that require immediate or\nurgent action. Submittals must be made promptly after the information becomes\navailable from the vendor.\n5. Monthly Reports. Submit monthly reports to the Director that: (1) include available data\nand results of the testing and evaluations required by the Safety Order; and (2) describe\nthe progress of the repairs and other remedial actions being undertaken.\n6. Documentation. It is requested, but not mandated, that the City maintain documentation\nof the safety improvement costs associated with fulfilling this Safety Order and submit\nthe total to the Director. It is requested that these costs be reported in two categories: (1)\ntotal cost associated with preparation/revision of plans, procedures, studies and analyses;\nand (2) total cost associated with replacements, additions and other changes to pipeline\ninfrastructure.\n\n\n\n4\nOn April 6, 2012, the City submitted its first monthly status report confirming that the mandated\nmonthly leak survey had been conducted on March 28, 2012, and that no leaks had been\ndetected. Also, on March 28, 2012, the maximum operating pressure was measured at 455 psig,\nwhich is less than the limitation proposed in the Notice of Proposed Safety Order (80% pressure\nreduction). Finally, the City confirmed that it had requested City Council approval for the\nconstruction work involved with the planned ILI tool run.\nOn May 7, 2012, the City submitted a second monthly status report confirming that a monthly\nleak test had been conducted on April 30, 2012. No leaks were detected. In addition, the City\nstated that the maximum operating pressure for the month of April was 456 psig, which is less\nthan the limitation proposed in the Notice of Proposed Safety Order (80% pressure reduction).\nIn your correspondence on this matter, please refer to CPF No. 5-2012-0004S and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. § 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. § 552(b).\nThe Director may grant an extension of time for compliance with any of the terms of the Safety\nOrder, upon a written request timely submitted and demonstrating good cause for an extension.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nThe actions taken pursuant to this Safety Order are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199,\nunder any other order issued to Respondent under authority of 49 U.S.C. chapter 601, or under\nany other provision of Federal or state law.\nAfter receiving and analyzing additional data in the course of this proceeding, PHMSA may\nidentify other safety measures that the City needs to take. In that event, Respondent will be\nnotified of any proposed additional measures and, if necessary, amendments to the Safety Order.\nThe terms and conditions of this Safety Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\n___________________________________ _______________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n520120004S_closure letter_08062013_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 6, 2013\nMr. Carlos R. Fandino, Jr.\nDirector, Light & Power Department\nCity of Vernon\n4305 Santa Fe Avenue\nVernon, CA 90058\nCPF 5-2012-0004S\nClosure Letter\nDear Mr. Fandino:\nOn May 30, 2012, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued\nthe City of Vernon a Safety Order in the above-referenced case. The purpose of this Order was\nto address pipeline integrity risk concerns, and included requirements to take corrective actions\non your pipeline. Based on our review of the documentation you provided, it has been\ndetermined that you have complied with the terms of this Order as detailed below:\n1) Leak Surveys.\nThe City of Vernon’s gas operations personnel performed leak surveys on monthly basis\nand reported the results on monthly report to PHMSA. No gas leaks were reported. The\nlast survey was reported on July 3, 2013.\n2) Maximum Allowable Operating Pressure Reduction.\nThe City of Vernon’s gas transmission pipeline pressure never exceeded 520 psig per the\nSafety Order restrictions. The highest pressure reported was 505 psig in November 2012.\n3) Removal of 3.1 miles from service.\nThe City of Vernon completed the removal of the 3.1 miles segment of the transmission\nline on February 7, 2013.\n\n\n\n4) In Line Inspection (ILI) Results.\nA successful ILI tool run by Enduro Pipeline Services, Inc. was reported on May 7, 2013\nwith no immediate or urgent action required. The lateral line to the power plant surveyed\nby Mistras on January 10, 2013, using the guide wave technology, was also reported\nwithout any issues. Reports have been submitted to the Western Region Director.\n5) Monthly reports.\nThe City of Vernon has submitted reports on a monthly basis. The last report was dated\nJuly 30, 2013.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 P.Nguyen","truncated":false,"body_characters":15222}