{"operation":"document","citation":"CPF 520190009M","title":"LONG BEACH GAS DEPT, CITY OF — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-02-07","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(2), 192.615(a)(3)(i), 192.615(a)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190009m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190009m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190009m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520190009M","body":"Notice of Amendment involving LONG BEACH GAS DEPT, CITY OF. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(2),  192.615(a)(3)(i),  192.615(a)(4). The case was opened on 2019-02-07 and is reported as closed as of 2019-07-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520190009M_Closure Letter_07012019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190009M/520190009M_Closure%20Letter_07012019.pdf\n\n520190009M_Closure Letter_07012019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190009M/520190009M_Closure%20Letter_07012019_text.pdf\n\n520190009M_Notice of Amendment_02072019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190009M/520190009M_Notice%20of%20Amendment_02072019.pdf\n\n520190009M_Notice of Amendment_02072019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190009M/520190009M_Notice%20of%20Amendment_02072019_text.pdf\n\n520190009M_Operator Response to Notice_03042019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190009M/520190009M_Operator%20Response%20to%20Notice_03042019.pdf\n\n520190009M_Closure Letter_07012019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 1, 2019\nMr. Robert Dowell\nDirector\nCity of Long Beach Energy Resources Department\n2400 East Spring Street\nLong Beach, CA 90806-2285\nCPF 5-2019-0009M\nClosure Letter\nDear Mr. Dowell:\nFrom July 16 through 20, 2018, representatives of the California Public Utilities Commission\n(CPUC), on behalf of the Pipeline and Hazardous Materials Safety Administration (PHMSA),\npursuant to Chapter 601 of 49 United States Code, conducted an on-site pipeline safety\ninspection of the City of Long Beach Energy Resources Department’s (LBER) operations,\nmaintenance and emergency procedures for its natural gas distribution system in Long Beach,\nCalifornia. As a result of the inspection, LBER was issued a Notice of Amendment on\nFebruary 7, 2019, which proposed amendment of your procedures.\nLBER submitted its amended procedures on May 29, 2019. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have\nbeen corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 N. Cruz (#163435)\n\n520190009M_Notice of Amendment_02072019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 7, 2019\nMr. Robert Dowell\nDirector\nCity of Long Beach Gas & Oil\n2400 East Spring Street\nLong Beach, CA 90806-2285\nCPF 5-2019-0009M\nDear Mr. Dowell:\nFrom July 16 through 20, 2018, representatives of the California Public Utilities Commission\n(CPUC) on behalf of the Pipeline and Hazardous Materials Safety Administration (PHMSA),\npursuant to Chapter 601 of 49 United States Code, inspected and reviewed your City of Long\nBeach Gas & Oil (LBGO) procedures for operations and maintenance (O&M) of the natural\ngas distribution system in Long Beach, California.\nBased on our inspection findings, CPUC identified apparent inadequacies within LBGO’s\nplans or procedures, as described below:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) . . .\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of Subpart I of this part.\n\n\n\nLBGO’s O&M Manual did not have adequate procedures for corrosion control in accordance\nwith §192.463(a). Specifically, the O&M Manual failed to address how to compensate for\nvoltage (IR) drop or the use of the 100 millivolt shift criteria, when determining the adequacy\nof the cathodic protection being provided to buried metallic pipelines. Furthermore, LBGO’s\nO&M Manual did not establish adequate procedures for external corrosion control monitoring\nin accordance with §192.465(a). LBGO failed to clearly define what constitutes separately\nprotected short sections of mains or transmission lines, or separately protected service lines.\n2. §192.615 Emergency Plans\n(a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas emergency. At a minimum, the procedures must provide for\nthe following:\n(1) …\n(3) Prompt and effective response to a notice of each type of emergency, including\nthe following: (i) Gas detected inside or near a building. (ii) …\nLBGO did not establish adequate written procedures in their Emergency Response Plan\n(ERP) to demonstrate LBGO has a prompt and effective response to a notice of emergency.\nLBGO’s ERP, Part 2 – Emergency Response Plan for Minor Emergencies, Section V –\n“Emergency Procedures During Normal Working Hours,” failed to explain in sufficient detail\nhow it would effectuate a prompt and effective response, with the availability of personnel,\nand to respond 24/7 (after normal working hours and weekends) to a gas emergency.\n3. §192.615 Emergency Plans\n(a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas emergency. At a minimum, the procedures must provide for\nthe following:\n(1) …\n(4) The availability of personnel, equipment, tools, and materials, as needed at\nthe scene of an emergency.\nLBGO did not establish adequate written procedures that ensures the availability of personnel,\nequipment, tools and materials from all City departments, as needed at the scene of an\nemergency, during normal working hours and outside normal working hours/weekends.\n2\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised 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\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must 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\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue an Order Directing\nAmendment. If your plans or procedures are found inadequate as alleged in this Notice, you\nmay be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. §\n190.206). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 60 days of receipt of this Notice. This period may be extended\nby written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that City of Long Beach Gas & Oil maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Chris Hoidal, Acting\nDirector, Western Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 5-2019-0009M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChris Hoidal\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 N. Cruz (#163435)\n3","truncated":false,"body_characters":8375}