# PANHANDLE EASTERN PIPELINE CO — Warning Letter

- **operation:** document
- **citation:** CPF 120191012W
- **title:** PANHANDLE EASTERN PIPELINE CO — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-07-11
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.12(d).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-120191012w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120191012w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120191012w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120191012W
**body:**

Warning Letter involving PANHANDLE EASTERN PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 192.12(d). The case was opened on 2019-07-11 and is reported as closed as of 2019-07-11. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120191012W_Operator Response to Notice_08092019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191012W/120191012W_Operator%20Response%20to%20Notice_08092019.pdf

120191012W_Warning Letter_07112019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191012W/120191012W_Warning%20Letter_07112019.pdf

120191012W_Warning Letter_07112019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191012W/120191012W_Warning%20Letter_07112019_text.pdf

120191012W_Warning Letter_07112019_text.pdf

WARNING LETTER
OVERNIGHT EXPRESS DELIVERY
July 11, 2019
Mr. Eric Amundsen
Senior Vice President, Operations
Panhandle Eastern Pipeline Company
1300 Main Street, Suite 2.050
Houston, TX 77002
CPF 1-2019-1012W
Dear Mr. Amundsen:
On April 23-25th, 2019, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected
Panhandle Eastern Pipeline Company’s (Panhandle) Howell Underground Storage Facility (UGS)
in Howell, MI.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violation are:



CPF 1-2019-1012W
1. §192.12 (d) Underground natural gas storage facilities.
(d) Each underground natural gas storage facility that uses a depleted hydrocarbon
reservoir or an aquifer reservoir for gas storage, including those constructed not
later than July 18, 2017 must meet the operations, maintenance, integrity
demonstration and verification, monitoring, threat and hazard identification,
assessment, remediation, site security, emergency response and preparedness, and
recordkeeping requirements and recommendations of API RP 1171, sections 8, 9,
10, and 11 (incorporated by reference, see §192.7) by January 18, 2018.
Panhandle failed to monitor for the presence of annular gas as directed by API RP 1171, Section
9.3.2.
Section 9.3.2 of API RP 1171, Well Integrity Monitoring, states:
The operator shall monitor for presence of annular gas by measuring and recording annular
pressure and/or annular gas flow.
During the field inspection at Howell UGS field, PHMSA discovered that Panhandle was unable
to monitor for the presence of annular gas at the surface due to a lack of pressure test ports or other
means of measuring annular gas flow.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$213,268 per violation per day the violation persists, up to a maximum of $2,132,679 for a related
series of violations. For violation occurring on or after November 2, 2015 and before November
27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum
penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015, the
maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to
exceed $2,000,000 for a related series of violations. We have reviewed the circumstances and
supporting documents involved in this case, and have decided not to conduct additional
enforcement action or penalty assessment proceedings at this time. We advise you to correct the
item(s) identified in this letter. Failure to do so will result in Panhandle Eastern Pipeline Compnay
being subject to additional enforcement action.
Please be advised that all material you submit in response to this enforcement action is subject to
being made publicly available. If you believe that any portion of your responsive material qualifies
for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you
must provide a second copy of the document with the portions you believe qualify for confidential
treatment redacted and an explanation of why you believe the redacted information qualifies for
confidential treatment under 5 U.S.C. 552(b).
120191012W_Warning Letter_07112019_text Page 2 of 3



CPF 1-2019-1012W
No reply to this letter is required. If you choose to reply, please submit all correspondence in this
matter to Robert Burrough, Director, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300,
West Trenton, NJ 08628. Please refer to CPF 1-2019-1012W on each document you submit, and
whenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed
to robert.burrough@dot.gov. Larger files should be sent on USB flash drive accompanied by the
original paper copy to the Eastern Region Office.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
120191012W_Warning Letter_07112019_text Page 3 of 3
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