{"operation":"document","citation":"CPF 120180008M","title":"COOK INLET NATURAL GAS STORAGE ALASKA — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-11-29","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120180008m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120180008m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120180008m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120180008M","body":"Notice of Amendment involving COOK INLET NATURAL GAS STORAGE ALASKA. PHMSA's enforcement data identifies the cited regulation as 192.12(e). The case was opened on 2018-11-29 and is reported as closed as of 2019-03-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120180008M_Closure Letter_03192019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180008M/120180008M_Closure%20Letter_03192019.pdf\n\n120180008M_Closure Letter_03192019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180008M/120180008M_Closure%20Letter_03192019_text.pdf\n\n120180008M_Notice of Amendment_11292018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180008M/120180008M_Notice%20of%20Amendment_11292018.pdf\n\n120180008M_Notice of Amendment_11292018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180008M/120180008M_Notice%20of%20Amendment_11292018_text.pdf\n\n120180008M_Operator Response to Notice_12212018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180008M/120180008M_Operator%20Response%20to%20Notice_12212018.pdf\n\n120180008M_Closure Letter_03192019_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMarch 19, 2019\nMr. John Lau\nVice President of Operations\nCook Inlet Natural Gas Storage Alaska\n3000 Spenard Road\nAnchorage, AK 99519\nCPF 1-2018-0008M\nDear Mr. Lau:\nFrom July 31 to August 2, 2018, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of Title 49 of the United States Code, inspected\nCook Inlet Natural Gas Storage Alaska’s (Cook Inlet) procedures and records for the Cannery Row\nUnderground Natural Gas Storage field in Kenai Peninsula County, Alaska.\nAs a result of the inspection, Cook Inlet was issued a Notice of Amendment (NOA) on November\n29, 2018.\nOn December 21, 2018, Cook Inlet responded to the NOA and submitted documentation showing\nit took certain actions to ensure compliance with the terms of the Notice.\nBased on our review of the documentation, it appears that the inadequacies outlined in this NOA\nhave been corrected.\nThis letter is to inform you no further action is necessary, and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120180008M_Notice of Amendment_11292018_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nNovember 29, 2018\nMr. John Lau\nVice President of Operations\nCook Inlet Natural Gas Storage Alaska\n3000 Spenard Road\nAnchorage, AK 99503\nCPF 1-2018-0008M\nDear Mr. Lau:\nFrom July 31 to August 2, 2018, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Cook Inlet\nNatural Gas Storage Alaska (Cook Inlet) procedures and records for the Cannery Row\nUnderground Natural Gas Storage field in Kenai Peninsula County, Alaska.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nCook Inlet’s plans or procedures, as described below:\n1. §192.12 (e) Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to §192.605.\nCook Inlet’s procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Cook Inlet’s\nprocedures do not define an annular pressure threshold to determine if additional evaluation is\nrequired as stated in API RP 1171, Section 9.3. In addition, Cook Inlet’s procedures do not state\nwhat measures must be undertaken if that threshold is met as stated in API RP 1171, Section 9.3.\n2. §192.12 (e) Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\n\n\n\nCPF 1-2018-0008M\n3. pursuant to §192.605.\nCook Inlet’s procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Cook Inlet does\nnot have the proper definition of an incident as stated in Part 192.3.\n§192.12 (e) Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to §192.605.\nCook Inlet’s procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Cook Inlet is\nmissing procedures to address Accidental Releases, Equipment Failure, Third Party Emergencies,\nand Natural Disasters as stated in API RP 1171, Section 10.6.1.\n4. §192.12 (e) Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to §192.605.\nCook Inlet’s procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Cook Inlet does\nnot have a procedure for the mitigation of external corrosion on casing in exposed piping within\ntheir well pits as stated in API RP 1171, Section 9.3.\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 Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 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 Notice\n120180008M_Notice of Amendment_11292018_text Page 2 of 3\n\n\n\nCPF 1-2018-0008M\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 90 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Cook Inlet Natural Gas Storage Alaska maintain documentation\nof the safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nEastern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 1-2018-0008M and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\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\ncc: Mr. Rusty Allen, Compliance Engineer, Cook Inlet Natural Gas Storage Alaska\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120180008M_Notice of Amendment_11292018_text Page 3 of 3","truncated":false,"body_characters":9446}