# SACRAMENTO MUNICIPAL UTILITY DISTRICT — Notice of Amendment

- **operation:** document
- **citation:** CPF 520190022M
- **title:** SACRAMENTO MUNICIPAL UTILITY DISTRICT — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-09-03
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.605(b)(2).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520190022m.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520190022m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520190022m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520190022M
**body:**

Notice of Amendment involving SACRAMENTO MUNICIPAL UTILITY DISTRICT. PHMSA's enforcement data identifies the cited regulation as 192.605(b)(2). The case was opened on 2019-09-03 and is reported as closed as of 2019-12-13. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520190022M_Closure Letter_12132019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190022M/520190022M_Closure%20Letter_12132019.pdf

520190022M_Closure Letter_12132019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190022M/520190022M_Closure%20Letter_12132019_text.pdf

520190022M_Notice of Amendment_09032019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190022M/520190022M_Notice%20of%20Amendment_09032019.pdf

520190022M_Notice of Amendment_09032019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190022M/520190022M_Notice%20of%20Amendment_09032019_text.pdf

520190022M_Operator Response to Notice_09302019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190022M/520190022M_Operator%20Response%20to%20Notice_09302019.pdf

520190022M_Closure Letter_12132019_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 13, 2019
Mr. Brad Jones
Manager, Thermal Generation & Gas Pipeline Assets
Sacramento Municipal Utility District
4401 Bradshaw Road
Sacramento, CA 95827
CPF 5-2019-0022M
Closure Letter
Dear Mr. Jones:
On July 22 through 26, 2019, representatives of the California Public Utilities Commission on behalf
of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of
49 United States Code, inspected Sacramento Municipal Utility District (SMUD) procedures for the
natural gas transmission system in Sacramento, California. As a result of the inspection, SMUD was
issued a Notice of Amendment on September 3, 2019, which proposed amendment of your
procedures.
SMUD submitted its amended procedures on September 30, 2019. My staff reviewed the amended
procedures, and 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 (#166441)
Dennis Lee, CPUC

520190022M_Notice of Amendment_09032019_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 3, 2019
Mr. Frankie McDermott
Chief Energy Delivery Officer
Sacramento Municipal Utility District
4401 Bradshaw Rd.
Sacramento, CA 95827
CPF 5-2019-0022M
Dear Mr. McDermott:
On July 22 through 26, 2019, representatives of the California Public Utilities Commission on
behalf of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to
Chapter 601 of 49 United States Code, inspected Sacramento Municipal Utility District (SMUD)
procedures for the natural gas transmission system in Sacramento, California.
On the basis of the inspection, PHMSA has identified an apparent inadequacy found within
SMUD’s plans or procedures, as described below:
1. §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.
§192.465(d) requires SMUD to take prompt remedial action to correct any deficiencies indicated
by the external corrosion control monitoring. SMUD’s procedure is missing specific language on



the timely correcting of cathodic protection (CP) deficiencies within the 15-month inspection
interval.1
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).
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 SMUD maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,
procedures) and submit the total to Dustin Hubbard, Director, Western Region, Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer
to CPF 5-2019-0022M and, for each document you submit, please provide a copy in electronic
format whenever possible.
Sincerely,
Dustin Hubbard
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 (#166441)
1 SMUD is encouraged but not required to specifically include targeted or required timeframes for correcting
deficiencies.
2
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