{"operation":"document","citation":"CPF 120190003W","title":"NORTHWEST NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-03-04","effective_on":null,"summary":"CLOSED warning letter citing 192.12(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120190003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120190003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120190003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120190003W","body":"Warning Letter involving NORTHWEST NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.12(d). The case was opened on 2019-03-04 and is reported as closed as of 2019-03-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120190003W_Warning Letter_03042019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120190003W/120190003W_Warning%20Letter_03042019.pdf\n\n120190003W_Warning Letter_03042019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120190003W/120190003W_Warning%20Letter_03042019_text.pdf\n\n120190003W_Warning Letter_03042019_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMarch 4, 2019\nMr. Jon Huddleston\nVice President, Engineering and Utility Operations\nNorthwest Natural Gas Co\n220 N.W. Second Avenue\nPortland, OR 97209\nCPF 1-2019-0003W\nDear Mr. Huddleston:\nFrom October 30 through November 1, 2018, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Northwest Natural Gas Co’s (NWN) MIST Underground Natural Gas Storage Field\n(MIST UGS Field). The inspection was was conducted at the NWN offices in Portland, Oregon\nand the MIST UGS Field located 55 miles northwest of Portland in Columbia county, Oregon.\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 items inspected\nand the probable 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.\nNWN failed to meet the applicable requirements and recommendations of API RP 1171, section\n10. Specifically, NWN did not have permanent weatherproof signs installed at the MIST UGS\n\n\n\nCPF 1-2019-0003W\nField at each well site for identification purposes as required by API RP 1171, Section 10.4.1.\nAPI RP 1171, Section 10.4.1, Minimum Signage Information, states in part:\nPermanent weatherproof signage shall be installed at each well site for identification\npurposes.\nDuring the field inspection at the MIST UGS Field, PHMSA discovered that NWN did not have\npermanent weatherproof signs installed at the following well sites:\n 23adh-3\n 33ac-3\n 23ach-3\n 33-3\n 33d-3\n 44-3\nNo reply to this letter is required. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion of\nyour responsive 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).\nNo reply to this letter is required. If you choose to reply, please submit all correspondence in this\nmatter to Robert Burrough, Director, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300,\nWest Trenton, NJ 08628. Please refer to CPF 1-2019-0003W on each document you submit, and\nwhenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed\nto robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original\npaper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120190003W_Warning Letter_03042019_text Page 2 of 2","truncated":false,"body_characters":4078}