{"operation":"document","citation":"CPF 520170009W","title":"SILICON VALLEY POWER — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-07-28","effective_on":null,"summary":"CLOSED warning letter citing 191.17(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170009w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170009w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170009w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520170009W","body":"Warning Letter involving SILICON VALLEY POWER. PHMSA's enforcement data identifies the cited regulation as 191.17(a). The case was opened on 2017-07-28 and is reported as closed as of 2017-07-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520170009W_Warning Letter_07282017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170009W/520170009W_Warning%20Letter_07282017.pdf\n\n520170009W_Warning Letter_07282017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170009W/520170009W_Warning%20Letter_07282017_text.pdf\n\n520170009W_Warning Letter_07282017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 28, 2017\nMr. Chet Manchester\nDivisional Manager of Generation\nSilicon Valley Power\n850 Duane Avenue\nSanta Clara, CA 95050\nCPF 5-2017-0009W\nDear Mr. Manchester:\nOn April 24 through 27, 2017, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nDonald Von Raesfeld Power Plant Pipeline System in Santa Clara, California.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items\ninspected and the probable violation is:\n1. §191.17 Transmission systems; gathering systems; liquefied natural gas facilities;\nand underground natural gas storage facilities: Annual report.\n(a) Transmission or Gathering. Each operator of a transmission or a gathering\npipeline system must submit an annual report for that system on DOT Form\nPHMSA 7100.2.1. This report must be submitted each year, not later than March\n15, for the preceding calendar year, except that for the 2010 reporting year the\nreport must be submitted by June 15, 2011.\n\n\n\nSilicon Valley Power (SVP) failed to comply with §191.17(a) by not reporting the full extent\nof their transmission system. In addition to their reported system, SVP has a 4-inch tap line\nconnected to the 12-inch pipeline at the fence line of the Donald Von Raesfeld power plant.\nThere is no method of isolation between the 4-inch and 12-inch lines, only a valve above\nground on the 4-inch line. This length of 4-inch line has not been incorporated into any prior\nannual report.\nAs of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a\ncivil penalty not to exceed $209,002 per violation per day the violation persists up to a\nmaximum of $2,090,022 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the item(s) identified in this letter. Failure to do so will result in Silicon\nValley Power being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2017-0009W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nDustin Hubbard\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 C. Carroll /H. Nguyen (#155246)","truncated":false,"body_characters":3762}