{"operation":"document","citation":"CPF 120180007W","title":"DOMINION ENERGY OHIO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-11-23","effective_on":null,"summary":"CLOSED warning letter citing 192.12(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120180007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120180007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120180007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120180007W","body":"Warning Letter involving DOMINION ENERGY OHIO. PHMSA's enforcement data identifies the cited regulation as 192.12(d). The case was opened on 2018-11-23 and is reported as closed as of 2018-11-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120180007W_Operator Response to Notice_01102019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180007W/120180007W_Operator%20Response%20to%20Notice_01102019.pdf\n\n120180007W_Warning Letter_11232018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180007W/120180007W_Warning%20Letter_11232018.pdf\n\n120180007W_Warning Letter_11232018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180007W/120180007W_Warning%20Letter_11232018_text.pdf\n\n120180007W_Warning Letter_11232018_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nNovember 23, 2018\nMr. Jim Eck\nVice President & General Manager\nDominion Energy Ohio\n1201 East 55th Street\nCleveland, OH 44103\nCPF 1-2018-0007W\nDear Mr. Eck:\nFrom June 19 through 21, 2018, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nDominion Energy Ohio’s (DEO) Gabor and Chippewa Underground Natural Gas Storage Fields\nin Wayne County, Ohio.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation(s) are:\n1. §192.12 (d) Underground natural gas storage facilities.\n(d) Each underground natural gas storage facility that uses a depleted hydrocarbon\nreservoir or an aquifer reservoir for gas storage, including those constructed not later\nthan July 18, 2017 must meet the operations, maintenance, integrity demonstration\nand verification, monitoring, threat and hazard identification, assessment,\nremediation, site security, emergency response and preparedness, and recordkeeping\nrequirements and recommendations of API RP 1171, sections 8, 9, 10, and 11\n(incorporated by reference, see §192.7) by January 18, 2018.\nDEO had not requested pertinent well data from the operators of 3rd party wells within the buffer\nzone of the Chippewa and Gabor Wertz storage fields as required by API RP 1171, Section 9.3.1.\nAPI RP 1171, Section 9.3.1, states in part “The operator shall request well integrity evaluation\n\n\n\nCPF 1-2018-0007W\ndata from third-party well owner/operators following the frequency established using conclusions\nfrom the risk assessment.”\nDuring the inspection at DEO’s office, DEO demonstrated that they had a template letter for\nrequesting pertinent well data from operators of 3rd party wells. DEO stated that the template letter\nhad not been updated with DEO’s information, nor sent to any operators of 3rd party wells within\nthe buffer zone of the Chippewa and Gabor Wertz fields.\n2. §192.12 (d) Underground natural gas storage facilities.\n(d) Each underground natural gas storage facility that uses a depleted hydrocarbon\nreservoir or an aquifer reservoir for gas storage, including those constructed not later\nthan July 18, 2017 must meet the operations, maintenance, integrity demonstration\nand verification, monitoring, threat and hazard identification, assessment,\nremediation, site security, emergency response and preparedness, and recordkeeping\nrequirements and recommendations of API RP 1171, sections 8, 9, 10, and 11\n(incorporated by reference, see §192.7) by January 18, 2018.\nDEO did not have records available of function tests, maintenance, repair and replacement of\nwellhead valves for the Chippewa and Gabor Wertz storage fields as required by API RP 1171,\nSection 9.3.2, and DEO’s Storage Operating Well Head Valve Maintenance Procedure.\nAPI RP 1171, Section 9.3.2, states in part “The operator shall test the operation of the master valve\nand wellhead pipeline isolation valve at least annually for proper function and ability to isolate the\nwell. The valves shall be maintained, repaired, or replaced in accordance with the operator’s valve\nmaintenance program for isolation valves.”\nDuring the inspection at DEO’s office, DEO stated that the system for recordkeeping of function\ntests, maintenance, repair and replacement of wellhead valves was in the process of being\nimplemented.\n3. §192.12 (d) Underground natural gas storage facilities.\n(d) Each underground natural gas storage facility that uses a depleted hydrocarbon\nreservoir or an aquifer reservoir for gas storage, including those constructed not later\nthan July 18, 2017 must meet the operations, maintenance, integrity demonstration\nand verification, monitoring, threat and hazard identification, assessment,\nremediation, site security, emergency response and preparedness, and recordkeeping\nrequirements and recommendations of API RP 1171, sections 8, 9, 10, and 11\n(incorporated by reference, see §192.7) by January 18, 2018.\nDEO did not have records available of training for personnel at the Chippewa and Gabor Wertz\nstorage fields as required by API RP 1171, Section 11.13.2.\nAPI RP 1171, Section 11.13.2, states in part “The operator shall maintain records that demonstrate\ncompliance with this subsection.”\nDuring the inspection at DEO’s office, DEO stated that the system for recordkeeping of training\nwas in the process of being implemented.\n120180007W_Warning Letter_11232018_text Page 2 of 3\n\n\n\nCPF 1-2018-0007W\nUnder 49 United States Code, § 60122 and 49 CFR § 190.223, you are subject to a civil penalty\nnot to exceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022\nfor a related series of violations. For violation occurring prior to November 2, 2015, the maximum\npenalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed\n$2,000,000 for a related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the items identified in\nthis letter. Failure to do so will result in Dominion Energy Ohio being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2018-0007W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nPlease note, the address for the PHMSA Eastern Region, Office of Pipeline Safety, has changed:\nPHMSA, Eastern Region, Office of Pipeline Safety\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\nPlease make a note of this new information in your records. If you have any questions, please\ncontact us at 609-771-7800.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120180007W_Warning Letter_11232018_text Page 3 of 3","truncated":false,"body_characters":7356}