{"operation":"document","citation":"CPF 120181020W","title":"CRESTWOOD MIDSTREAM PARTNERS LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-09-20","effective_on":null,"summary":"CLOSED warning letter citing 192.12(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181020w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181020w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181020w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120181020W","body":"Warning Letter involving CRESTWOOD MIDSTREAM PARTNERS LP. PHMSA's enforcement data identifies the cited regulation as 192.12(d). The case was opened on 2018-09-20 and is reported as closed as of 2018-09-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120181020W_Warning Letter_09202018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181020W/120181020W_Warning%20Letter_09202018.pdf\n\n120181020W_Warning Letter_09202018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181020W/120181020W_Warning%20Letter_09202018_text.pdf\n\n120181020W_Warning Letter_09202018_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nSeptember 20, 2018\nMs. Farrah Lowe\nSenior Vice President, ESR, Land & Outreach\nCrestwood Midstream Partners LP\n811 Main Street.\nHouston, TX 77002\nCPF 1-2018-1020W\nDear Ms. Lowe:\nFrom April 17 to 19, 2018, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Crestwood\nMidstream Partners LP (Crestwood) Stagecoach Underground Natural Gas Storage (UGS) Field\nin Tioga County, New York.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\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.\nCrestwood failed to monitor annular pressure, as required by API RP 1171 Section 9.3.2, at 4 wells\nin the UGS Field.\n\n\n\nCPF 1-2018-1020W\nAPI RP 1171, Section 9.3.2, states in part “The operator shall monitor for presence of annular gas\nby measuring and recording annular pressure and/or annular gas flow”.\nDuring the field inspection at Stagecoach UGS field, PHMSA discovered that Crestwood was\nunable to monitor the annular pressure at multiple wells due to inaccessible valves (either buried\nor under water). The wells that were unable to be monitored included the following:\n Barnhart #1\n Lacker 0-1\n N. Mead 1A\n Well L1\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related\nseries of violations. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000\nfor a related series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Crestwood being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2018-1020W. 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).\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120181020W_Warning Letter_09202018_text Page 2 of 2","truncated":false,"body_characters":4209}