CITY OF VERNON — Notice of Amendment

party submissionOfficial PDF52021053NOA_Operator Response to Notice_02252022_(20-195538).pdf#

52021053NOA_Notice of Amendment_12172021_(20-195538)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT VIA E-MAIL TO MR. CARLOS FANDINO December 17, 2021 Mr. Carlos Fandino City Administrator City of Vernon 4305 Santa Fe Ave. Vernon, CA 90058 CPF 5-2021-053-NOA Dear Mr. Fandino: On October 12 through 16, 2020, a representative 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 the City of Vernon’s (Vernon) written procedures for its natural gas transmission system located in Vernon, California. On the basis of the inspection, PHMSA has identified apparent inadequacies found within Vernon’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.#

52021053NOA_Notice of Amendment_12172021_(20-195538)_text.pdf, page 2Vernon's procedures are inadequate to assure safe operation of a pipeline facility. Specifically, they do not include procedures for establishing the maximum allowable operating pressure (MAOP) for a pipeline segment in accordance with §192.619, located in subpart L of Part 192.1 The procedures state the desired MAOP and details how to conduct a pressure test of a pipeline segment. The procedures do not, however, explain how Vernon will establish MAOP using the lowest pressure calculated using the methods set forth under § 192.619 (c), (d), or (e). This requirement applies to both the distribution and transmission systems. Vernon must amend its procedures to include the method Vernon uses to establish the MAOP for each pipeline segment in accordance with §192.619. 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. Vernon's procedures are inadequate to assure safe operation of a pipeline facility. Specifically, Vernon's O&M plan does not include a requirement that the MAOP of a pipeline segment be confirmed or revised within 24 months whenever the hoop stress corresponding to the established MAOP is determined not to be commensurate with the existing class location pursuant to § 192.611(d), located in subpart L of Part 192.2 Vernon must amend its procedure to require that confirmation or revision of the MAOP, as required as a result of a study under § 192.609, must be completed within 24 months of the change in class location. 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 1 § 192.619 Maximum allowable operating pressure: Steel or plastic pipelines. (a) No person may operate a segment of steel or plastic pipeline at a pressure that exceeds a maximum allowable operating pressure (MAOP) determined under paragraph (c), (d), or (e) of this section… 2 § 192.611 - Change in class location: Confirmation or revision of maximum allowable operating pressure. (a)… (d) Confirmation or revision of the maximum allowable operating pressure that is required as a result of a study under § 192.609 must be completed within 24 months of the change in class location. Pressure reduction under paragraph (a) (1) or (2) of this section within the 24-month period does not preclude establishing a maximum allowable operating pressure under paragraph (a)(3) of this section at a later date. 2#

52021053NOA_Notice of Amendment_12172021_(20-195538)_text.pdf, page 3U.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 Vernon 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 5-2021-053-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 (#20-195538) Terrence Eng, Program Manager, Gas Safety and Reliability Branch California Public Utilities Commission 3#

52021053NOA_Closure Letter_03212022_(20-195538)_text.pdf, page 1Official PDFVIA E-MAIL TO MR. CARLOS FANDINO March 21, 2022 Mr. Carlos Fandino City Administrator City of Vernon 4305 Santa Fe Avenue Vernon, CA 90058 CPF 5-2021-052-NOA CPF 5-2021-053-NOA Closure Letter Dear Mr. Fandino: On October 12 through 16, 2020, a representative 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 the City of Vernon’s (Vernon) written procedures for its natural gas transmission and distribution systems located in Vernon, California. As a result of the inspection, Vernon was issued two Notices of Amendment on December 17, 2021, which proposed amendment of your procedures. Vernon submitted its amended procedures on February 25, 2022 in response to both Notices. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in both Notices of Amendment have been corrected. This letter is to inform you that no further action is necessary and these cases are 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 (#20-173128, #20-195538) Angela Kimmey, Deputy City Administrator, City of Vernon, akimmey@cityofvernon.org Terrence Eng, Program Manager, Gas Safety and Reliability Branch, California Public Utilities Commission#