# CITY OF SUSANVILLE — Warning Letter

- **operation:** document
- **citation:** CPF 520150010W
- **title:** CITY OF SUSANVILLE — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2015-07-06
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.616(a), 192.616(b), 192.616(c).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520150010w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520150010w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520150010W
**body:**

Warning Letter involving CITY OF SUSANVILLE. PHMSA's enforcement data identifies the cited regulations as 192.616(a),  192.616(b),  192.616(c). The case was opened on 2015-07-06 and is reported as closed as of 2015-07-06. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520150010W_warning letter_07062015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150010W/520150010W_warning%20letter_07062015.pdf

520150010W_warning letter_07062015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150010W/520150010W_warning%20letter_07062015_text.pdf

520150010W_warning letter_07062015_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 6, 2015
Mr. Craig C. Platt
Public Works Director
City of Susanville
720 South Street
Susanville, CA 96130-3904
CPF 5-2015-0010W
Dear Mr. Platt:
PHMSA conducted an internal audit of its past regulatory inspection and discovered that this
enforcement letter was not issued. PHMSA must ensure that all violations revealed during
past inspection are provided to pipeline operators so they can remedy them. We apologize for
the tardiness of this letter but we need to ensure you address the regulatory deficiencies to
provide for public safety.
On June 28, 2012 a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
Public Awareness Program (PAP) in Susanville, California.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violations are:



1. §192.616 Public Awareness
(a) Except for an operator of a master meter or petroleum gas system covered
under paragraph (j) of this section, each pipeline operator must develop and
implement a written continuing public education program that follows the
guidance provided in the American Petroleum Institute's (API) Recommended
Practice (RP) 1162 (incorporated by reference, see § 192.7).
City of Susanville’s PAP did not include a written statement of management support, did not
name a program administrator, did not identify key personnel and their title, and did not
specified resources or founding allocations.
Each operator of hazardous liquid pipeline system, natural gas transmission pipeline system,
gathering pipeline system, or natural gas distribution pipeline system must establish (and
periodically update) a written PAP designed to cover all required components of the program
described in API RP 1162 Section 7.1. The written program must include:
a. A statement of management commitment to achieving effective public awareness.
b. A description of the roles and responsibilities of personnel administering the
program.
c. Identification of key personnel and their title (including senior management
responsible for the implementation, delivery, and ongoing development of the
program).
2. §192.616 Public Awareness
(b) The operator's program must follow the general program recommendations
of API RP 1162 and assess the unique attributes and characteristics of the
operator's pipeline and facilities.
The City of Susanville operates a natural gas distribution system consisting of 60 miles of
main distribution pipeline, 2942 service lines, and 10 regulator stations, but failed to include
these facilities as unique attributes to its system. Where appropriate, communications with
affected public and emergency and public officials in proximity of major facilities must
include information to promote understanding of the nature of the facility.
Each operator should communicate general information regarding the facility and products
stored or transported through the facility, as described in API RP 1162 Section 4.12.
Attributes and characteristics include items such as transmission, distribution, gathering, the
pipe’s physical properties (diameter, wall thickness, etc.), the number of pipelines in the right-
of-way (ROW), the location of the above ground facilities along the ROW, and the chemical
and physical properties of the products transported.
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3. §192.616 Public Awareness
(c) The operator must follow the general program recommendations, including
baseline and supplemental requirements of API RP 1162, unless the operator
provides justification in its program or procedural manual as to why compliance
with all or certain provisions of the recommended practice is not practicable and
not necessary for safety.
City of Susanville failed to identify the baseline and supplemental message delivery
frequency and message delivery methods for all stakeholder audience groups as required by
API RP 1162, table 2-2. PAP communications frequencies, as required by API RP 1162, for
local natural gas distribution (LDC) companies are:
a. b. c. d. e. f. Once a year for Affected Public
Twice a year for LDC customers
Once a year for Emergency Officials
Once every 3 years for Public Officials
Once a years for Excavator Contractors
As applicable for One-Call Centers
Each of the primary stakeholder audiences must be considered independently by the operator
when determining the delivery method. Operators may use one or more delivery methods for
each of the primary stakeholder audiences and that selection of delivery method is designed to
assure all the intended stakeholders receive at least one PAP message during each delivery
period.
4. §192.616 Public Awareness
(c) The operator must follow the general program recommendations, including
baseline and supplemental requirements of API RP 1162, unless the operator
provides justification in its program or procedural manual as to why compliance
with all or certain provisions of the recommended practice is not practicable and
not necessary for safety.
City of Susanville did not consider and/or implemente supplemental program enhancements
as required by API RP 1162 Section 6.2. When the operator develops its PAP and performs
subsequent periodic program evaluations, it is recommended that a step for assessing relevant
factors along the pipeline route be included to consider what components of the PAP should
be enhanced. Each operator must consider each of the factors, specified in API RP 1162, and
apply them along the entire route of the pipeline system.
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5. §192.616 Public Awareness
(c) The operator must follow the general program recommendations, including
baseline and supplemental requirements of API RP 1162, unless the operator
provides justification in its program or procedural manual as to why compliance
with all or certain provisions of the recommended practice is not practicable and
not necessary for safety.
The City of Susanville failed to establish an annual evaluation process to review its PAP
according to the guidelines in API RP 1162. The City did not perform an annual audit each
year after initial program implementation in July 31, 2006. The operator should complete an
annual audit or review of whether the program has been developed and implemented. The
purpose of the audit is to make sure:
a. The PAP been developed and written to address the objectives, elements and
baseline schedule as described in API RP 1162 Section 2.
b. The PAP been implemented and documented to the written program.
Each operator must use self-assessment, third-party, or regulatory inspections as an alternative
methodology when completing an annual audit or program implementation.
6. §192.616 Public Awareness
(c) The operator must follow the general program recommendations, including
baseline and supplemental requirements of API RP 1162, unless the operator
provides justification in its program or procedural manual as to why compliance
with all or certain provisions of the recommended practice is not practicable and
not necessary for safety.
The City of Susanville did not have a process determining program changes or modifications
based on results of the evaluation to improve PAP effectiveness according to the guidelines in
API RP 1162. The City did not perform an effectiveness evaluation of its PAP since the
initial program implementation in July 31, 2006. An effective evaluation was due by July 30,
2010. Each operator should assess progress on the following measures to assess whether the
actions undertaken in implementation of API RP 1162 are achieving the intended goals and
objectives:
a. b. c. d. Whether the information is reaching the intended stakeholder audiences.
If the recipient audiences are understanding the message delivered
Whether the recipients are motivated to respond appropriately in alignment with
the information provided
If the implementation of the PAP is impacting the bottom-line results.
4



Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a
related series of violations. For violations occurring prior to January 4, 2012, the maximum
penalty may not exceed $100,000 per violation per day, with a maximum penalty not to
exceed $1,000,000 for a 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.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2015-0010W. 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).
PHMSA does apologize for any inconvenience or confusion that this delayed enforcement
letter might cause. If there are any questions concerning this letter, please do not hesitate to
contact me at (720) 963-3160. Thank you for your cooperation in this matter.
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 H. Monfared (#139070)
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