ISLAND ENERGY — Notice of Amendment

party submissionOfficial PDF52020003NOA_Operator Response to Notice_11092020_(20-173118).pdf#

52020003NOA_Closure Letter_02112021_(20-173118)_text.pdf, page 1Official PDFVIA E-MAIL TO MR. GARRETT EVANS February 11, 2021 Mr. Garrett Evans City Manager City of Pittsburg 65 Civic Avenue Pittsburg, CA 94565 CPF 5-2020-003-NOA Closure Letter Dear Mr. Evans: On February 24 through 28, 2020, representatives 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 (U.S.C.), inspected your natural gas distribution system (Island Energy) on Mare Island in Vallejo, California. As a result of the inspection, Island Energy was issued a Notice of Amendment on October 16, 2020, which proposed amendment of your procedures. Island Energy submitted its amended procedures on November 9, 2020. 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 (#20-173118) Doug Buchanan, General Manager Island Energy 995 Walnut Ave. Vallejo, CA 94592 Terrence Eng, Program Manager, Gas Safety and Reliability Branch, California Public Utilities Commission#

52020003NOA_Notice of Amendment_10162020_(20-173118)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT VIA E-MAIL TO MR. GARRETT EVANS October 16, 2020 Mr. Garrett Evans City Manager City of Pittsburg 65 Civic Avenue Pittsburg, CA 94565 CPF 5-2020-003-NOA Dear Mr. Evans: On February 24 through 28, 2020, representatives 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 (U.S.C.), inspected your natural gas distribution system (Island Energy) on Mare Island in Vallejo, California. On the basis of the inspection, PHMSA has identified an apparent inadequacy found within Island Energy’s plans or procedures, as described below: 1. §192.805 Qualification program. Each operator shall have and follow a written qualification program. The program shall include provisions to: (a) … (i) After December 16, 2004, notify the Administrator or a state agency participating under 49 U.S.C. Chapter 601 if the operator significantly modifies the program after the administrator or state agency has verified that it complies with this section. Notifications to PHMSA may be submitted by electronic mail to InformationResourcesManager@dot.gov, or by mail to ATTN: Information Resources Manager DOT/PHMSA/OPS, East Building, 2nd Floor, E22-321, New Jersey Avenue SE., Washington, DC 20590. 1#

52020003NOA_Notice of Amendment_10162020_(20-173118)_text.pdf, page 2The Island Energy Operator Qualifications manual does not contain a procedure for notifying the CPUC, a state agency participating under 49 U.S.C. Chapter 601, if the operator significantly modifies the program after the CPUC has verified that it complies with Section 192.805. In the Reporting/Notification section of the Island Energy Operator Qualification manual, it states that, “All Plan revisions that effect operations, maintenance and emergency response procedures are to be communicated to all appropriate personnel at the earliest opportunity.” Island Energy should revise this section to clearly state that the CPUC must be notified and how to make such notifications for significant OQ program changes. 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 30 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 Island Energy 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 5-2020-003-NOA and, for each document you submit, please provide a copy 2#

52020003NOA_Notice of Amendment_10162020_(20-173118)_text.pdf, page 3in electronic format whenever possible. Please copy the CPUC Program Manager on all correspondence. 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 (#20-173118) Terrence Eng, Program Manager, Gas Safety and Reliability Branch, California Public Utilities Commission Doug Buchanan, General Manager Island Energy, 995 Walnut Ave., Vallejo, CA 94592 3#