{"operation":"document","citation":"CPF 52021012NOA","title":"LONG BEACH GAS DEPT, CITY OF — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-02-19","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021012noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021012noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021012noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52021012NOA","body":"Notice of Amendment involving LONG BEACH GAS DEPT, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.605(b)(1). The case was opened on 2021-02-19 and is reported as closed as of 2021-04-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52021012NOA_Closure Letter_04152021_(20-173126).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021012NOA/52021012NOA_Closure%20Letter_04152021_(20-173126).pdf\n\n52021012NOA_Closure Letter_04152021_(20-173126)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021012NOA/52021012NOA_Closure%20Letter_04152021_(20-173126)_text.pdf\n\n52021012NOA_Notice of Amendment_02192021_(20-173126).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021012NOA/52021012NOA_Notice%20of%20Amendment_02192021_(20-173126).pdf\n\n52021012NOA_Notice of Amendment_02192021_(20-173126)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021012NOA/52021012NOA_Notice%20of%20Amendment_02192021_(20-173126)_text.pdf\n\n52021012NOA_Operator Response to Notice_03152021_(20-173126).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021012NOA/52021012NOA_Operator%20Response%20to%20Notice_03152021_(20-173126).pdf\n\n52021012NOA_Notice of Amendment_02192021_(20-173126)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA E-MAIL TO MR. ROBERT DOWELL\nFebruary 19, 2021\nMr. Robert Dowell\nDirector\nCity of Long Beach Gas & Oil\n2400 East Spring Street\nLong Beach, CA 90806-2285\nCPF 5-2021-012-NOA\nDear Mr. Dowell:\nOn August 31 through September 4, 2020, representatives of the California Public Utilities\nCommission (CPUC), on behalf of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected and reviewed your City\nof Long Beach Gas & Oil (LBGO) procedures for operations and maintenance (O&M) of the\nnatural gas distribution system in Long Beach, California.\nBased on our inspection findings, CPUC identified apparent inadequacies within LBGO's plans\nor procedures, as described below:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis 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 of\nthe requirements of this subpart and subpart M of this part.\n1\n\n\n\nLBGO’s Gas Operations and Maintenance (GO&M) procedures, Section No. Maint-3.2, Gas\nOdorization, describes the process LBGO uses to ensure the appropriate odorant levels are\ncontained in the natural gas provided to LBGO customers, in accordance with §192.625. Section\n4.10 addresses, \"Personnel performing sniff tests,\" but does not include any procedures regarding\nactivity restrictions prior to personnel performing such tests. The manufacturer of the odorant\ntesting equipment recommends the operator follow ASTM D6273-14, Standard Test Methods for\nNatural Gas Odor Intensity. This standard includes activity restrictions, specifically regarding\neating and drinking, for personnel performing odorant tests because such activities can impact\nthe effectiveness of sniff tests. LBGO, however, failed to include such restrictions in its GO&M\nprocedures. It is recommended that LBGO include the activity restrictions in ASTM D6273-14\nfor performing odorant tests in the GO&M procedures, including a minimum time after a\nrestricted activity before personnel can perform a sniff test in order to ensure the test is effective.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis 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 of\nthe requirements of this subpart and subpart M of this part.\nSection No. 1.2. of the GO&M procedures addresses “Vault Maintenance of vaults having a\nvolume of 200 cubic feet or more.” This section describes inspection and maintenance of vaults,\nas well as the requirements for housing equipment in vaults. There is no provision, however,\nwithin the GO&M procedure to address abnormal operation conditions, such as when a vault is\nsubmerged under liquids or when a vault contains liquids or hazardous materials. It is\nrecommended that LBGO amend its vault maintenance procedures to address abnormal\noperating conditions, including the issues of submerged vaults and of vaults containing liquids or\nhazardous materials to assure safe operation of LBGO’s pipeline facilities.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. 552(b).\n2\n\n\n\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 of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n30 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that the City of Long Beach Gas & Oil maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Dustin Hubbard, Director,\nWestern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 5-2021-012-NOA and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nDustin Hubbard\nDirector, 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 (# 20-173126)\nTerrence Eng, Program Manager, Gas Safety and Reliability Branch, California Public\nUtilities Commission\n3\n\n52021012NOA_Closure Letter_04152021_(20-173126)_text.pdf\n\nVIA E-MAIL TO MR. ROBERT DOWELL\nApril 15, 2021\nMr. Robert Dowell\nDirector\nCity of Long Beach Gas & Oil\n2400 East Spring Street\nLong Beach, CA 90806-2285\nCPF 5-2021-012-NOA\nClosure Letter\nDear Mr. Dowell:\nOn August 31 through September 4, 2020, representatives of the California Public Utilities Commission\n(CPUC), on behalf of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to\nChapter 601 of 49 United States Code, inspected and reviewed your City of Long Beach Gas & Oil\n(LBGO) procedures for operations and maintenance (O&M) of the natural gas distribution system in\nLong Beach, California. As a result of the inspection, LBGO was issued a Notice of Amendment on\nFebruary 19, 2021, which proposed amendment of your procedures.\nLBGO submitted its amended procedures on March 15, 2021. 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 your\ncooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Dunphy (#20-173126)\nTerrence Eng, Program Manager, Gas Safety and Reliability Branch, California Public Utilities\nCommission","truncated":false,"body_characters":8852}