{"operation":"document","citation":"CPF 120190002M","title":"GRAMA RIDGE STORAGE AND TRANSPORTATION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-02-12","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120190002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120190002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120190002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120190002M","body":"Notice of Amendment involving GRAMA RIDGE STORAGE AND TRANSPORTATION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(e). The case was opened on 2019-02-12 and is reported as closed as of 2019-06-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120190002M_Closure Letter_06042019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120190002M/120190002M_Closure%20Letter_06042019.pdf\n\n120190002M_Closure Letter_06042019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120190002M/120190002M_Closure%20Letter_06042019_text.pdf\n\n120190002M_Notice of Amendment_02122019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120190002M/120190002M_Notice%20of%20Amendment_02122019.pdf\n\n120190002M_Notice of Amendment_02122019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120190002M/120190002M_Notice%20of%20Amendment_02122019_text.pdf\n\n120190002M_Operator Response to Notice_04252019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120190002M/120190002M_Operator%20Response%20to%20Notice_04252019.pdf\n\n120190002M_Notice of Amendment_02122019_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nFebruary 12, 2019\nMr. Ben Moore\nVice President Operations and Engineering\nGrama Ridge Storage and Transportation, LLC\n20329 State Highway 249, Suite 400\nHouston, TX 77070\nCPF 1-2019-0002M\nDear Mr. Moore:\nFrom September 11 to 13, 2018, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nGrama Ridge Storage and Transportation, LLC’s (Grama Ridge) procedures and records for the\noperation of the Enstor Grama Natural Gas Storage Field in Hobbs, New Mexico and at the\nEnstor Grama storage field located 40 miles southwest of Hobbs in Lea County, New Mexico.\nBased on the results of the inspection, PHMSA has identified the apparent inadequacies found\nwithin the Grama Ridge’s Underground Natural Gas Storage (UNGS) procedures, as described\nbelow:\n1. § 192.12 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.\nGrama Ridge’s written procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1171 were inadequate. Specifically, Grama Ridge procedures do not state\nhow they will evaluate each annular gas occurrence that exceeds operator-defined threshold levels\ndetermined from well integrity evaluation and from risk assessments as required in API RP 1171,\n\n\n\nCPF 1-2019-0002M\n2. Section 9.3.2, for the wells at Enstor Grama.\nAPI RP 1171, Section 9.3.2 Well Integrity Monitoring, states in part:\nThe operator shall monitor for presence of annular gas by measuring and recording annular\npressure and/or annular gas flow. The operator shall evaluate each annular gas occurrence\nthat exceeds operator- or regulatory-defined threshold levels determined from well\nintegrity evaluation and from risk assessment.\n§ 192.12 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.\nGrama Ridge’s written procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1171 were inadequate. Specifically, Grama Ridge does not have\nprocedures for maintaining, repairing, or replacing isolation valves as required in API RP 1171,\nSection 9.3.2, for the wells at Enstor Grama.\nAPI RP 1171, Section 9.3.2 Well Integrity Monitoring, states in part:\nThe operator shall visually inspect each wellhead assembly at least annually for leaks. The\noperator shall test the operation of the master valve and wellhead pipeline isolation valve\nat least annually for proper function and ability to isolate the well. The valves shall be\nmaintained, repaired, or replaced in accordance with the operator’s valve maintenance\nprogram for isolation valves.\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\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\n120190002M_NOA_02122019 (160087) Page 2 of 3\n\n\n\nCPF 1-2019-0002M\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 60 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 Grama Ridge Storage and Transportation, LLC maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough,\nDirector, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628.\nPlease refer to CPF 1-2019-0002M on each document you submit, and whenever possible provide\na signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov.\nLarger files should be sent on a CD accompanied by the original paper copy to the Eastern Region\nOffice.\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120190002M_NOA_02122019 (160087) Page 3 of 3\n\n120190002M_Closure Letter_06042019_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJune 4, 2019\nMr. Paul Bieniawski\nChief Executive Officer\nEnstor, Inc.\n10375 Richmond Avenue, Suite 1900\nHouston, TX 77042\nCPF 1-2019-0002M\nDear Mr. Bieniawski:\nFrom September 11 to 13, 2018, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nGrama Ridge Storage and Transportation, LLC’s (Grama Ridge) procedures and records for the\noperation of the Enstor Grama Natural Gas Storage Field in Hobbs, New Mexico and at the\nEnstor Grama storage field located 40 miles southwest of Hobbs in Lea County, New Mexico.\nAs a result of the inspection, Grama Ridge was issued a Notice of Amendment on February 12,\n2019, which proposed amendment of your procedures.\nGrama Ridge submitted its amended procedures on April 25, 2019. My 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":8783}