{"operation":"document","citation":"CPF 520160014","title":"COALINGA, CITY OF — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-08-31","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.463(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160014.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160014.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160014","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520160014","body":"Notice of Probable Violation involving COALINGA, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.463(a). The case was opened on 2016-08-31 and is reported as closed as of 2017-08-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520160014_Final Order_08242017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160014/520160014_Final%20Order_08242017.pdf\n\n520160014_Final Order_08242017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160014/520160014_Final%20Order_08242017_text.pdf\n\n520160014_NOPV PCO_08312016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160014/520160014_NOPV%20PCO_08312016.pdf\n\n520160014_NOPV PCO_08312016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160014/520160014_NOPV%20PCO_08312016_text.pdf\n\n520160014_Operator Response to Notice_01302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160014/520160014_Operator%20Response%20to%20Notice_01302017.pdf\n\n520160014_Final Order_08242017_text.pdf\n\nAugust 24, 2017\nMr. Peter Preciado\nPublic Works and Utilities Director\nCity of Coalinga\n155 West Durian Avenue\nCoalinga, CA 93210\nRe: CPF No. 5-2016-0014\nDear Mr. Preciado:\nEnclosed please find the Final Order issued in the above-referenced case. It makes a finding of\nviolation and finds that the City of Coalinga has completed the actions specified in the Notice to\ncomply with the pipeline safety regulations. Therefore, this case is now closed. Service of the\nFinal Order by certified mail is effective upon the date of mailing as provided under 49 C.F.R.\n§ 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Director, Western Region, Office of Pipeline Safety, PHMSA\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____________________________________\n)\nIn the Matter of )\n)\nCity of Coalinga, California, ) CPF No. 5-2016-0014\na municipal corporation, )\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nFrom November 16 to 19, 2015, pursuant to 49 U.S.C. § 60117, representatives of the Pipeline\nand Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),\nconducted an on-site pipeline safety inspection of the facilities and records of the City of\nCoalinga (City or Respondent) in Coalinga, California. The City operates its own natural gas\ndistribution system.\nAs a result of the inspection, the Director, Western Region, OPS (Director), issued to\nRespondent, by letter dated August 31, 2016, a Notice of Probable Violation and Proposed\nCompliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed\nfinding that the City had violated 49 C.F.R. § 192.463 and proposed ordering Respondent to take\ncertain measures to correct the alleged violations.1\nAfter requesting and receiving an extension of time to respond, the City responded to the Notice\nby letter dated January 30, 2017 (Response). The City did not contest the allegation of violation\nand provided information concerning the corrective actions it had taken, including copies of its\nrevised procedures. In May 2017, a PHMSA representative conducted a subsequent on-site\ninspection of the City’s facilities and records in Coalinga. The subsequent inspection verified\nthat the revised procedures had been implemented by April 3, 2017. Respondent did not request\na hearing and therefore has waived its right to one.\n1 The Notice was issued in conjunction with a separate Notice of Amendment (CPF No. 5-2016-0013M). An Order\nDirecting Amendment in that case was issued separately on May 31, 2017.\n\n\n\nCPF No. 5-2016-0014\nPage 2\nFINDING OF VIOLATION\nIn its Response, the City did not contest the allegation in the Notice that it violated 49 C.F.R.\nPart 192, as follows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.463(a), which states:\n§ 192.463 External corrosion control: Cathodic protection.\n(a) Each cathodic protection system required by this subpart must\nprovide a level of cathodic protection that complies with one or more of the\napplicable criteria contained in appendix D of this part. If none of these\ncriteria is applicable, the cathodic protection system must provide a level of\ncathodic protection at least equal to that provided by compliance with one\nor more of these criteria.\n49 C.F.R. Part 192, Appendix D, provides, in relevant part:\nAPPENDIX D TO PART 192—CRITERIA FOR CATHODIC\nPROTECTION AND DETERMINATION OF MEASUREMENTS\nI. Criteria for cathodic protection— A. Steel, cast iron, and ductile iron\nstructures.\n(1) A negative (cathodic) voltage of at least 0.85 volt, with reference to\na saturated copper-copper sulfate half cell. Determination of this voltage\nmust be made with the protective current applied, and in accordance with\nsections II and IV of this appendix. . . . .\nII. Interpretation of voltage measurement. Voltage (IR) drops other than\nthose across the structure-electrolyte boundary must be considered for valid\ninterpretation of the voltage measurement in paragraphs A(1) and (2) and\nparagraph B(1) of section I of this appendix.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.463(a) by failing to maintain\nadequate cathodic protection (CP) of its pipeline system. Specifically, the Notice alleged that the\nCity did not have an adequate process for monitoring its CP system to ensure adequate\nprotection. The monitoring criteria used by the City to monitor its CP system did not consider IR\ndrops for pipe-to-soil readings, as required by 49 C.F.R. Appendix D, section II. Under\n49 C.F.R. Part 192, Appendix D, section I(A)(1), the City was required to use monitoring criteria\nto determine the negative (cathodic) voltage of at least 0.85 volt and to consider IR drop for pipe-\nto-soil readings. Respondent did not contest this allegation of violation. Accordingly, based\nupon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 192.463(a) by\nfailing to maintain adequate CP of its pipeline system.\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\n\n\n\nCPF No. 5-2016-0014\nPage 3\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Item 1 in the Notice for a violation of\n49 C.F.R. § 192.463(a). Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of gas or who owns or operates a pipeline facility is required to comply with the\napplicable safety standards established under chapter 601. The Director indicates that\nRespondent has taken the following actions specified in the proposed compliance order:\n1. With respect to the violation of § 192.463(a) (Item 1), Respondent has amended\nthe City’s Operations and Maintenance (O&M) Manual to consider voltage (IR)\ndrops for valid interpretation of the voltage measurement of pipe-to-soil readings.\n2. With respect to the violation of § 192.463(a) (Item 1), Respondent has written\nand implemented a process or procedure for considering voltage (IR) drop for\npipe-to-soil readings.\nAccordingly, I find that compliance has been achieved with respect to this violation. Therefore,\nthe compliance terms proposed in the Notice are not included in this Order.\nThe terms and conditions of this Final Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\nAugust 24, 2017\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":7709}