# COALINGA, CITY OF — Notice of Amendment

- **operation:** document
- **citation:** CPF 520190014M
- **title:** COALINGA, CITY OF — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-03-18
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.13(c), 192.605(b)(1), 192.605(b)(2), 192.615(a), 192.615(b)(3).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520190014m.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520190014m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520190014m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520190014M
**body:**

Notice of Amendment involving COALINGA, CITY OF. PHMSA's enforcement data identifies the cited regulations as 192.13(c),  192.605(b)(1),  192.605(b)(2),  192.615(a),  192.615(b)(3). The case was opened on 2019-03-18 and is reported as closed as of 2019-12-05. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520190014M_Closure Letter_12052019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190014M/520190014M_Closure%20Letter_12052019.pdf

520190014M_Closure Letter_12052019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190014M/520190014M_Closure%20Letter_12052019_text.pdf

520190014M_Notice of Amendment_03182019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190014M/520190014M_Notice%20of%20Amendment_03182019.pdf

520190014M_Notice of Amendment_03182019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190014M/520190014M_Notice%20of%20Amendment_03182019_text.pdf

520190014M_Operator Response to Notice_09242019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190014M/520190014M_Operator%20Response%20to%20Notice_09242019.pdf

520190014M_Notice of Amendment_03182019_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 18, 2019
Mayor Ron Lander
City of Coalinga
155 West Durian
Coalinga, CA 93210
CPF 5-2019-0014M
Dear Mayor Lander:
On August 7 and 8, 2018, a representative of the California Public Utilities Commission
(CPUC), on behalf of the Pipeline and Hazardous Materials Safety Administration (PHMSA),
pursuant to Chapter 601 of 49 United States Code, reviewed the City of Coalinga (Coalinga)
natural gas distribution system procedures for Operations and Maintenance (O&M).
The CPUC identified the apparent inadequacies within Coalinga’s plans or procedures, as
described below:
1. § 192.13 What general requirements apply to pipelines regulated under this
part?
(a) . . .
(c) Each operator shall maintain, modify as appropriate, and follow the plans,
procedures, and programs that it is required to establish under this part.
Section XVIII of the City of Coaling’s O&M Plan does not meet the requirements of
§ 192.383(b) & (d). Specifically, the O&M plan does not address excess flow valve (EFV)
installation at multifamily residences and fails to include procedures to inform any and all
customers (considering the exclusions of § 192.383) of their rights to request an EFV be
installed.



2. § 192.615 Emergency plans.
(a) Each operator shall establish written procedures to minimize the hazard
resulting from a gas pipeline emergency. . .
(b) Each operator shall:
(1) . . .
(3) Review employee activities to determine whether the procedures were
effectively followed in each emergency.
The Emergency Plan contained in the Coalinga O&M Plan does not contain a process to
review employee activities to determine whether the procedures were effectively followed in
each emergency, pursuant to § 192.615(b)(3).
3. § 192.13 What general requirements apply to pipelines regulated under this
part?
(a) . . .
(c) Each operator shall maintain, modify as appropriate, and follow the plans,
procedures, and programs that it is required to establish under this part.
The Coalinga O&M Plan pipeline pressure testing procedure does not meet the requirements
of 49 CFR 192 Sub-Part J. Specifically, the procedure does not address the testing of new or
replacement mains.
4. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . .
(b) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance with each of
the requirements of this subpart and subpart M of this part.
The Coalinga O&M Plan does not contain a process addressing valve maintenance
requirements in § 192.747(b), found in subpart M of Part 192. Specifically, the O&M Plan
does not require prompt remedial action for valves found inoperable.
5. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . .
(b) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) . . .
2



(2) Controlling corrosion in accordance with the operations and maintenance
requirements of subpart I of this part.
The Visual Inspection of Gas main subsection in Section XI of the Coalinga O&M Plan does
not meet the requirements of § 192.459, found in subpart I of Part 192. Specifically, there is
no language requiring further inspection of the exposed pipe (either longitudinally or
circumferentially) if corrosion requiring remedial action under § 192.487 is found.
6. § 192.605 Procedural manual for operations, maintenance, and emergencies
(a) . . .
(b) Maintenance and normal operations. The manual required by paragraph (a)
of this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) . . .
(2) Controlling corrosion in accordance with the operations and maintenance
requirements of Subpart I of this part.
The O&M Plan does not have procedures that address the requirements of § 192.463, found in
Subpart I. Specifically, § 192.463(a) requires that operators “provide a level of cathodic
protection that complies with one or more of the applicable criteria contained in Appendix D
of this part.” The Coalinga O&M Plan, however, does not contain a process to address
voltage (IR) drops required by § 192.463(a). In addition, § 192.463(b) requires that operators
inspect rectifiers “six times each year, but with intervals not exceeding 2 ½ months.” Section
XI of the Coalinga O&M Plan does not meet these requirements.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed
as part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. 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).
3



Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §190.211. If you do not respond within 30 days
of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in
this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as
alleged in this Notice without further notice to you and to issue an Order Directing
Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you
may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. §
190.206). If you are not contesting this Notice, we propose that you submit your amended
procedures to my office within 60 days of receipt of this Notice. This period may be extended
by written request for good cause. Once the inadequacies identified herein have been
addressed in your amended procedures, this enforcement action will be closed.
It is requested (not mandated) that The City of Coalinga maintain documentation of the safety
improvement costs associated with fulfilling this Notice of Amendment (preparation/revision
of plans, procedures) and submit the total to Chris Hoidal, Acting Director, Western Region,
Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this
matter, please refer to CPF 5-2019-0014M and, for each document you submit, please
provide a copy in electronic format to PHP-WRADMIN@dot.gov whenever possible.
Sincerely,
Chris Hoidal
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
cc: PHP-60 Compliance Registry
PHP-500 J. Dunphy (#162964)
Mr. Pete Preciado
Public Works Director
City of Coalinga
155 West Durian Avenue
Coalinga, CA 93210
4

520190014M_Closure Letter_12052019_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 5, 2019
Mayor Ron Lander
City of Coalinga
155 West Durian
Coalinga, CA 93210
CPF 5-2019-0014M
Closure Letter
Dear Mayor Lander:
On August 7 and 8, 2018, a representative of the California Public Utilities Commission (CPUC), on
behalf of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter
601 of 49 United States Code, reviewed the City of Coalinga’s (Coalinga) natural gas distribution
system procedures for Operations and Maintenance (O&M). As a result of the inspection, Coalinga
was issued a Notice of Amendment on March 18, 2019, which proposed amendment of your
procedures.
The CPUC reviewed Coalinga’s amended procedures during their recent inspection in June 2019, and
on September 24, 2019 Coalinga submitted these revised procedures to PHMSA.
It appears that the inadequacies outlined in this Notice of Amendment have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you for
your cooperation.
Sincerely,
Dustin Hubbard
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Dunphy (#162964)
Dennis Lee, CPUC
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