LONG BEACH GAS DEPT, CITY OF — Notice of Amendment

party submissionOfficial PDF52021012NOA_Operator Response to Notice_03152021_(20-173126).pdf#

52021012NOA_Notice of Amendment_02192021_(20-173126)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT VIA E-MAIL TO MR. ROBERT DOWELL February 19, 2021 Mr. Robert Dowell Director City of Long Beach Gas & Oil 2400 East Spring Street Long Beach, CA 90806-2285 CPF 5-2021-012-NOA Dear Mr. Dowell: On August 31 through September 4, 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, inspected and reviewed your City of Long Beach Gas & Oil (LBGO) procedures for operations and maintenance (O&M) of the natural gas distribution system in Long Beach, California. Based on our inspection findings, CPUC identified apparent inadequacies within LBGO'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) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and subpart M of this part. 1#

52021012NOA_Notice of Amendment_02192021_(20-173126)_text.pdf, page 2LBGO’s Gas Operations and Maintenance (GO&M) procedures, Section No. Maint-3.2, Gas Odorization, describes the process LBGO uses to ensure the appropriate odorant levels are contained in the natural gas provided to LBGO customers, in accordance with §192.625. Section 4.10 addresses, "Personnel performing sniff tests," but does not include any procedures regarding activity restrictions prior to personnel performing such tests. The manufacturer of the odorant testing equipment recommends the operator follow ASTM D6273-14, Standard Test Methods for Natural Gas Odor Intensity. This standard includes activity restrictions, specifically regarding eating and drinking, for personnel performing odorant tests because such activities can impact the effectiveness of sniff tests. LBGO, however, failed to include such restrictions in its GO&M procedures. It is recommended that LBGO include the activity restrictions in ASTM D6273-14 for performing odorant tests in the GO&M procedures, including a minimum time after a restricted activity before personnel can perform a sniff test in order to ensure the test is effective. 2. §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. Section No. 1.2. of the GO&M procedures addresses “Vault Maintenance of vaults having a volume of 200 cubic feet or more.” This section describes inspection and maintenance of vaults, as well as the requirements for housing equipment in vaults. There is no provision, however, within the GO&M procedure to address abnormal operation conditions, such as when a vault is submerged under liquids or when a vault contains liquids or hazardous materials. It is recommended that LBGO amend its vault maintenance procedures to address abnormal operating conditions, including the issues of submerged vaults and of vaults containing liquids or hazardous materials to assure safe operation of LBGO’s pipeline facilities. 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). 2#

52021012NOA_Notice of Amendment_02192021_(20-173126)_text.pdf, page 3Following 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 the City of Long Beach Gas & Oil 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 5-2021-012-NOA 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 (# 20-173126) Terrence Eng, Program Manager, Gas Safety and Reliability Branch, California Public Utilities Commission 3#

52021012NOA_Closure Letter_04152021_(20-173126)_text.pdf, page 1Official PDFVIA E-MAIL TO MR. ROBERT DOWELL April 15, 2021 Mr. Robert Dowell Director City of Long Beach Gas & Oil 2400 East Spring Street Long Beach, CA 90806-2285 CPF 5-2021-012-NOA Closure Letter Dear Mr. Dowell: On August 31 through September 4, 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, inspected and reviewed your City of Long Beach Gas & Oil (LBGO) procedures for operations and maintenance (O&M) of the natural gas distribution system in Long Beach, California. As a result of the inspection, LBGO was issued a Notice of Amendment on February 19, 2021, which proposed amendment of your procedures. LBGO submitted its amended procedures on March 15, 2021. 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 (#20-173126) Terrence Eng, Program Manager, Gas Safety and Reliability Branch, California Public Utilities Commission#