{"operation":"document","citation":"CPF 520190015M","title":"CITY OF SUSANVILLE — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-03-18","effective_on":null,"summary":"CLOSED notice of amendment citing 192.16(b), 192.605(b)(1), 192.605(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190015m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190015m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190015m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520190015M","body":"Notice of Amendment involving CITY OF SUSANVILLE. PHMSA's enforcement data identifies the cited regulations as 192.16(b),  192.605(b)(1),  192.605(b)(2). The case was opened on 2019-03-18 and is reported as closed as of 2019-08-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520190015M_Closure Letter_08142019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190015M/520190015M_Closure%20Letter_08142019.pdf\n\n520190015M_Closure Letter_08142019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190015M/520190015M_Closure%20Letter_08142019_text.pdf\n\n520190015M_Notice of Amendment_03182019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190015M/520190015M_Notice%20of%20Amendment_03182019.pdf\n\n520190015M_Notice of Amendment_03182019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190015M/520190015M_Notice%20of%20Amendment_03182019_text.pdf\n\n520190015M_Operator Response to Notice_05282019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190015M/520190015M_Operator%20Response%20to%20Notice_05282019.pdf\n\n520190015M_Notice of Amendment_03182019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 18, 2019\nMayor Kevin Stafford\nCity of Susanville\n66 North Lassen Street\nSusanville, CA 96130\nCPF 5-2019-0015M\nDear Mayor Stafford:\nOn October 23-25, 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, reviewed the Operations and Maintenance\n(O&M) procedures for the City of Susanville’s (Susanville) natural gas distribution system.\nThe CPUC identified the apparent inadequacies within Susanville’s plans or procedures, as\ndescribed below:\n1. § 192.16 Customer notification.\n(a) . . .\n(b) Each operator shall notify each customer once in writing of the following\ninformation:\n(1) The operator does not maintain the customer's buried piping.\n(2) If the customer's buried piping is not maintained, it may be subject to the\npotential hazards of corrosion and leakage.\n(3) Buried gas piping should be—\n(i) Periodically inspected for leaks;\n(ii) Periodically inspected for corrosion if the piping is metallic; and\n(iii) Repaired if any unsafe condition is discovered.\n\n\n\n§ 192.605 Procedural manual for operations, maintenance, and emergencies\n(4) When excavating near buried gas piping, the piping should be located in\nadvance, and the excavation done by hand.\n(5) The operator (if applicable), plumbing contractors, and heating contractors\ncan assist in locating, inspecting, and repairing the customer's buried piping.\nSusanville’s process for customer notification does not meet the requirements of\n§ 192.16(b)because it does not contain the required information listed in § 192.16(b)(1)\nthrough (5).\n2. (a) . . .\n(b) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each\nof the requirements of this subpart and Subpart M of this part.\nThe Susanville O&M manual does not contain a process for the abandonment of vaults\npursuant to § 192.727, contained in Subpart M of Part 192, which requires that each\nabandoned vault be filled with a suitable compacted material. Additionally, the Susanville\nO&M manual does not contain a process for the inspection of vaults pursuant to § 192.749,\nalso contained in Subpart M of Part 192, which sets forth requirements for vault inspections\nand maintenance.\n3. § 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) . . .\n(b) Maintenance and normal operations. The manual required by paragraph (a)\nof this 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.\nThe Susanville O&M manual did not have sufficient procedures for external corrosion\ncontrol, nor internal corrosion control. Specifically, the Susanville O&M did not meet the\nrequirement of § 192.455(a)(2) External corrosion control: Buried or submerged pipelines\ninstalled after July 31, 1971, contained in Subpart I of Part 192. Section L of the O&M did\nnot explicitly require that each buried or submerged pipeline installed after July 31, 1971,\nhave a cathodic protection system designed to protect the pipeline in accordance with Subpart\nI installed and placed in operation within 1 year after completion of construction.\nAdditionally, the Susanville O&M did not meet the requirements of § 192.475 Internal\ncorrosion control: General, contained in Subpart I of Part 192. The Susanville O&M\nmanual requires in Section L-2 that internal corrosion inspections “be performed whenever\npossible, but not less than twice each year” [emphasis added]. Part 192 does not require\n2\n\n\n\ninternal corrosion inspections to occur at any frequency outside of an event that exposed the\ninterior surface of a pipeline. Susanville does not perform nor are they required to perform\nany internal corrosion inspections outside of events that exposed the interior surface of the\npipe. The O&M manual must comply with Federal regulations and reflect Susanville\noperating and maintenance practices.\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.\n3\n\n\n\nIt is requested (not mandated) that The City of Susanville maintain documentation of the\nsafety 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 5-2019-0015M and, for each\ndocument you submit, please provide a copy in electronic format to PHP-\nWRADMIN@dot.gov 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 J. Dunphy (#161682)\nMr. Dan Newton, Interim City Administrator\nCity of Susanville\n720 South Street\nSusanville, CA 96130\n4\n\n520190015M_Closure Letter_08142019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 14, 2019\nMr. Dan Newton\nPublic Works Director\nCity of Susanville\n720 South Street\nSusanville, CA 96130\nCPF 5-2019-0015M\nDear Mr. Newton:\nOn October 23 through 25, 2018, representatives of the California Public Utilities Commission on\nbehalf of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter\n601 of 49 United States Code, conducted an on-site pipeline safety inspection of The City of Susanville\n(Susanville) procedures in Susanville, California. As a result of the inspection, Susanville was issued a\nNotice of Amendment on March 18, 2019, which proposed amendment of your procedures.\nSusanville submitted its amended procedures on May 28, 2019. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you for\nyour cooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Regions\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Dunphy (#161682)\nDennis Lee, CPUC Program Manager","truncated":false,"body_characters":9448}