# CITY OF SUSANVILLE — Warning Letter

- **operation:** document
- **citation:** CPF 520120012W
- **title:** CITY OF SUSANVILLE — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2012-05-14
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 191.13.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520120012w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520120012w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520120012w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520120012W
**body:**

Warning Letter involving CITY OF SUSANVILLE. PHMSA's enforcement data identifies the cited regulation as 191.13. The case was opened on 2012-05-14 and is reported as closed as of 2012-05-14. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520120012W_Operator Response_05302012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520120012W/520120012W_Operator%20Response_05302012.pdf

520120012W_warning letter_05142012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520120012W/520120012W_warning%20letter_05142012.pdf

520120012W_warning letter_05142012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520120012W/520120012W_warning%20letter_05142012_text.pdf

520120012W_warning letter_05142012_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
May 14, 2012
Mr. Craig C. Platt
Public Works Director
City of Susanville
66 N. Lassen St.
Susanville, CA 96130
CPF 5- 2012-0012W
Dear Mr. Platt:
On March 19-21, 2012, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
natural gas pipeline system in Susanville, 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. §191.13 Distribution systems reporting transmission pipelines; transmission or
gathering systems reporting distribution pipelines.
Each operator, primarily engaged in gas distribution, who also operates gas
transmission or gathering pipelines shall submit separate reports for these
pipelines as required by §§ 191.15 and 191.17. Each operator, primarily
engaged in gas transmission or gathering, who also operates gas distribution
pipelines shall submit separate reports for these pipelines as required by §§
191.9 and 191.11.



At the time of the inspection, annual reports filed by the City of Susanville for its municipal
gas system did not separately report the gas transmission system supplying its distribution
system, as well as two large-volume customers – a power plant and a correctional facility. A
separate annual report should have been filed for the approximately 10.75 miles of 6” coated-
steel, cathodically-protected transmission line, operating at approximately 340 pounds per
square inch gauge (PSIG), with a maximum allowable operating pressure (MAOP) of 1000
PSIG.
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 the City of Susanville 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 5-2012-0012W. 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,
Christopher Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Stahoviak (#138162)
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