{"operation":"document","citation":"CPF 52025027NOA","title":"CPN PIPELINE COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2025-11-21","effective_on":null,"summary":"OPEN notice of amendment citing 192.467(a), 192.467(b), 192.467(c), 192.467(d), 192.467(e), 192.467(f), 192.615(a)(12), 192.635(a)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025027noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025027noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025027noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52025027NOA","body":"Notice of Amendment involving CPN PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.467(a),  192.467(b),  192.467(c),  192.467(d),  192.467(e),  192.467(f),  192.615(a)(12),  192.635(a)(1). The case was opened on 2025-11-21 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52025027NOA_Notice of Amendment_11212025_(24-297332).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025027NOA/52025027NOA_Notice%20of%20Amendment_11212025_(24-297332).pdf\n\n52025027NOA_Notice of Amendment_11212025_(24-297332)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025027NOA/52025027NOA_Notice%20of%20Amendment_11212025_(24-297332)_text.pdf\n\n52025027NOA_Notice of Amendment_11212025_(24-297332)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n12300 W. Dakota Ave., Suite 340\nLakewood, CO 80228\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: michael.delcasale@calpine.com\nNovember 21, 2025\nMr. Michael Del Casale\nExecutive V.P. of Power Operations\nCPN Pipeline Company\n717 Texas Avenue, Suite 1000\nHouston, TX 77002\nCPF 5-2025-027-NOA\nDear Mr. Del Casale:\nFrom September 9 through September 13, 2024, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code (U.S.C.) inspected CPN Pipeline Company’s (CPN) Northern CA\nGas System natural gas transmission and gathering pipeline system from Antioch to Yuba City,\nCalifornia.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nCPN’s plans or procedures. The items inspected and the inadequacies are described below:\n1. § 192.467 External corrosion control: Electrical isolation.\n(a) Each buried or submerged pipeline must be electrically isolated from other\nunderground metallic structures, unless the pipeline and the other structures are\nelectrically interconnected and cathodically protected as a single unit.\n(b) One or more insulating devices must be installed where electrical isolation of a\nportion of a pipeline is necessary to facilitate the application of corrosion control.\n(c) Except for unprotected copper inserted in ferrous pipe, each pipeline must be\nelectrically isolated from metallic casings that are a part of the underground system.\n\n\n\nHowever, if isolation is not achieved because it is impractical, other measures must\nbe taken to minimize corrosion of the pipeline inside the casing.\n(d) Inspection and electrical tests must be made to assure that electrical isolation is\nadequate.\n(e) An insulating device may not be installed in an area where a combustible\natmosphere is anticipated unless precautions are taken to prevent arcing.\n(f) Where a pipeline is located in close proximity to electrical transmission tower\nfootings, ground cables or counterpoise, or in other areas where fault currents or\nunusual risk of lightning may be anticipated, it must be provided with protection\nagainst damage due to fault currents or lightning, and protective measures must\nalso be taken at insulating devices.\nCPN’s procedures for electrical isolation were inadequate to ensure the safe operation of a\nnatural gas transmission or gathering pipeline. Specifically, a review of CPN’s Corrosion\nControl Manual, Section 8 revealed it did not contain procedures detailing the processes required\nfor electrical isolation from interference including a process for electrical isolation from metallic\ncasings and a process on how to conduct inspections and electrical tests to assure the electrical\nisolation was adequate. In addition, CPN’s Corrosion Control Manual did not contain what\nprecautions to prevent arcing, or protections against fault currents or lightning CPN was to\nutilize and maintain, even though CPN’s pipeline is located in an area where fault currents or\nunusual risks of lighting may be anticipated.\nAccordingly, PHMSA proposes CPN must amend its Corrosion Control Manual to meet the\nrequirements of § 192.467.\n2. § 192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas pipeline emergency. At a minimum, the procedures must\nprovide for the following:\n(1) …\n(12) Each operator must develop written rupture identification procedures to\nevaluate and identify whether a notification of potential rupture, as defined in\n§ 192.3, is an actual rupture event or a non-rupture event. These procedures must,\nat a minimum, specify the sources of information, operational factors, and other\ncriteria that operator personnel use to evaluate a notification of potential rupture\nand identify an actual rupture. For operators installing valves in accordance with\n§ 192.179(e), § 192.179(f), or that are subject to the requirements in § 192.634, those\nprocedures must provide for rupture identification as soon as practicable.\nCPN’s Operations and Maintenance Manual (O&M) was inadequate to ensure the safe operation\nof a natural gas transmission pipeline. Specifically, CPN’s O&M did not contain written rupture\nidentification procedures for its transmission pipelines. During inspection, PHMSA observed\nthat the O&M, Section 33A.5 stated that CPN was not subject to the rupture identification\nrequirements of § 192.615(a)(12) because no shut off segments per § 192.634 currently exist\nwithin its system. However, § 192.615(a)(12) does not specify that written rupture identification\n2\n\n\n\nprocedures only apply to shut-off segments pursuant to § 192.634. As such, CPN was required\nto develop written rupture identification procedures regardless of the presence of shut off\nsegments.\nAccordingly, PHMSA proposes CPN must amend its procedures to fully conform to the\nrequirements of § 192.615(a)(12).\n3. § 192.635 Notification of potential rupture.\n(a) As used in this part, a “notification of potential rupture” refers to the\nnotification of, or observation by, an operator (e.g., by or to its controller(s) in a\ncontrol room, field personnel, nearby pipeline or utility personnel, the public, local\nresponders, or public authorities) of one or more of the below indicia of a potential\nunintentional or uncontrolled release of a large volume of gas from a pipeline:\n(1) An unanticipated or unexplained pressure loss outside of the pipeline's normal\noperating pressures, as defined in the operator's written procedures. The operator\nmust establish in its written procedures that an unanticipated or unplanned\npressure loss is outside of the pipeline's normal operating pressures when there is a\npressure loss greater than 10 percent occurring within a time interval of 15 minutes\nor less, unless the operator has documented in its written procedures the operational\nneed for a greater pressure-change threshold due to pipeline flow dynamics\n(including changes in operating pressure, flow rate, or volume), that are caused by\nfluctuations in gas demand, gas receipts, or gas deliveries; or\nCPN’s O&M was inadequate to ensure the safe operation of a natural gas transmission pipeline.\nSpecifically, CPN’s O&M did not define unanticipated or unexplained pressure loss outside of\nthe pipeline’s normal operating pressures on its transmission lines. Section 23.2 of its O&M\nstates, “At this time CPN has no shut-off segment applicable to the RMV requirements. If and\nwhen this changes CPN will develop a site-specific procedure for identifying an unanticipated or\nunexplained pressure loss, flow rate change, pressure change, or equipment function outside of\nthe pipeline’s normal operating pressures, in accordance with § 192.635.” However, neither\n§ 192.3 nor § 192.635 specify that notification of potential rupture only applies to shut-off\nsegments pursuant to § 192.634. As such, CPN was required to define potential rupture\nregardless of the presence of shut off segments.\nAccordingly, PHMSA proposes CPN must amend its procedures to fully conform to the\nrequirements of § 192.635(a)(1).\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\nEnforcement 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\n3\n\n\n\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).\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 CPN maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Dustin Hubbard, Director, Western Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to\nCPF 5-2025-027-NOA, and for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 T. Dickey (#24-297332)\nScott Vickers, CPN Pipeline Company, Compliance Manager, svickers@calpine.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n4","truncated":false,"body_characters":10667}