{"operation":"document","citation":"CPF 120191013W","title":"NORTHERN NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-07-22","effective_on":null,"summary":"CLOSED warning letter citing 192.12(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191013w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191013w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191013w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120191013W","body":"Warning Letter involving NORTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.12(d). The case was opened on 2019-07-22 and is reported as closed as of 2019-07-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120191013W_Operator Response to Notice_07312019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191013W/120191013W_Operator%20Response%20to%20Notice_07312019.pdf\n\n120191013W_Warning Letter_07222019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191013W/120191013W_Warning%20Letter_07222019.pdf\n\n120191013W_Warning Letter_07222019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191013W/120191013W_Warning%20Letter_07222019_text.pdf\n\n120191013W_Warning Letter_07222019_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nJuly 22, 2019\nMr. Royce Ramsay\nVice President, Operations\nNorthern Natural Gas Company\n1111 South 103rd Street\nOmaha, NE 68124\nCPF 1-2019-1013W\nDear Mr. Ramsay:\nOn May 15-17, 2018, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nNorthern Natural Gas Company’s (NNG) Redfield Underground Storage Facility (UGS) in\nRedfield, IA.\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 are:\n1. § 192.12 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.\n\n\n\nCPF 1-2019-1013W\nNNG failed to meet the monitoring requirements of API RP 1171, section 9. Specifically, NNG\nfailed to evaluate each annular gas occurrence that exceeded operator-defined threshold levels\ndetermined from well integrity evaluation and from risk assessment, as directed by API RP 1171,\nSection 9.3.2.\nSection 9.3.2 of API RP 1171, Well Integrity Monitoring, states in part:\nThe operator shall evaluate each annular gas occurrence that exceeds operator- or\nregulatory-defined threshold levels determined from well integrity evaluation and from risk\nassessment.\nNNG’s Procedure 6.15.1, Annulus Pressure Monitoring, required a follow-up for 10 psi and greater\nannular pressure changes recorded during monthly readings.\nNNG's Procedure OI-003, Annulus Pressure Recording, dated 4/28/16 (OI-003), stated in part:\n6.5.4 The storage field will evaluate each occurrence that exceeds the established\nthreshold levels determined from well integrity evaluation and from risk assessment. The\noperator should test wellhead seals when annulus pressure is detected and where injectable\npacking and/or test ports are present.\n6.5.5 The storage field will prepare a monthly report to Pipeline Safety with the past two\nmonthly pressure readings per well with an assessment on whether the pressure readings\nexceed defined threshold levels and if a threshold was exceeded, actions taken or being\ntaken to address. The report will be stored in P8.\nDuring the field inspection at Redfield UGS facility, the PHMSA inspector reviewed records of\nNNG’s annular gas monitoring. The records demonstrated that NNG had not evaluated each\nannular gas occurrence that exceeded its established threshold of 10 psi and greater changes during\nmonthly monitoring, as required in NNG’s Procedure 6.15.1 and OI-003 Sections 6.5.4-6.5.5.\nTherefore, NNG failed to meet the monitoring requirements of API RP 1171, section 9.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$213,268 per violation per day the violation persists, up to a maximum of $2,132,679 for a related\nseries of violations. For violation occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015, the\nmaximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to\nexceed $2,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in Northern Natural Gas Company being\nsubject to additional enforcement action.\n120191013W_Warning Letter_07222019_text Page 2 of 3\n\n\n\nCPF 1-2019-1013W\nPlease be advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential 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 1-2019-1013W 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 USB flash drive accompanied by the\noriginal paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120191013W_Warning Letter_07222019_text Page 3 of 3","truncated":false,"body_characters":6307}