{"operation":"document","citation":"CPF 120181021M","title":"CRESTWOOD MIDSTREAM PARTNERS LP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-09-20","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181021m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181021m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181021m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120181021M","body":"Notice of Amendment involving CRESTWOOD MIDSTREAM PARTNERS LP. PHMSA's enforcement data identifies the cited regulation as 192.12(e). The case was opened on 2018-09-20 and is reported as closed as of 2018-11-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120181021M_Closure Letter_11192018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181021M/120181021M_Closure%20Letter_11192018.pdf\n\n120181021M_Closure Letter_11192018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181021M/120181021M_Closure%20Letter_11192018_text.pdf\n\n120181021M_Notice of Amendment_09202018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181021M/120181021M_Notice%20of%20Amendment_09202018.pdf\n\n120181021M_Notice of Amendment_09202018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181021M/120181021M_Notice%20of%20Amendment_09202018_text.pdf\n\n120181021M_Operator Response to Notice_10162018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181021M/120181021M_Operator%20Response%20to%20Notice_10162018.pdf\n\n120181021M_Notice of Amendment_09202018_text.pdf\n\nNOTICE OF AMENDMENT\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 1-2018-1021M\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’s (Crestwood) procedures and records for the Stagecoach Underground\nNatural Gas Storage field in Tioga County, New York.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nCrestwood’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.\nCrestwood’s procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Crestwood’s\nprocedures do not define an annular pressure threshold to determine if additional evaluation is\nrequired.\nCrestwood’s procedure, Section 2.29.4, states that the “Threshold for action will be an indicated\nloss of integrity”. This is not a defined threshold level and does not satisfy API RP 1171, Section\n\n\n\nCPF 1-2018-1021M\n9.3.2, which states in part that “The operator shall evaluate each annular gas occurrence that\nexceeds operator or regulatory-defined threshold levels determined from well integrity evaluation\nand risk assessment”.\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\npursuant to §192.605.\nCrestwood’s procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Crestwood does\nnot have a procedure to verify all applicable staff receive training in the use of the emergency\npreparedness/response plan as stated in API RP 1171, Section 10.6.2.\n3. §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.\nCrestwood’s procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Crestwood does\nnot have a procedure to measure the effectiveness of operator familiarity with emergency plans\nand procedures and periodic testing of the effectiveness of the plan in accordance with API RP\n1171, Section 11.4.2.\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.\nCrestwood’s procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Crestwood does\nnot have an adequate procedure in defining document retention, including training records, as\nrequired by API RP Section 11.13.3.\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\n120181021M_Notice of Amendment_09202018_text Page 2 of 3\n\n\n\nCPF 1-2018-1021M\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\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 Crestwood maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 1-2018-1021M and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nPlease note, effective September 24, 2018, the PHMSA Eastern Region, Office of Pipeline\nSafety, address will be as follows:\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\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120181021M_Notice of Amendment_09202018_text Page 3 of 3\n\n120181021M_Closure Letter_11192018_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nNovember 19, 2018\nMs. Victoria Wagner\nVice President, ESR\nCrestwood Midstream Partners LP\n811 Main Street, Suite 3400\nHouston, TX 77002\nCPF 1-2018-1021M\nDear Ms. Wagner:\nFrom April 17 to 19, 2018, representatives from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, inspected\nCrestwood Midstream Partners LP’s (Crestwood) procedures for the Stagecoach Underground\nNatural Gas Storage field in Tioga County, NY. As a result of the inspection, Crestwood was\nissued a Notice of Amendment on September 20, 2018, which proposed amendment of your\nprocedures.\nCrestwood submitted its amended procedures on October 16, 2018. PHMSA staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\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","truncated":false,"body_characters":9617}