{"operation":"document","citation":"CPF 120191023M","title":"TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP) — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-12-19","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191023m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191023m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191023m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120191023M","body":"Notice of Amendment involving TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP). PHMSA's enforcement data identifies the cited regulation as 192.12(e). The case was opened on 2019-12-19 and is reported as closed as of 2020-02-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120191023M_Closure Letter_02212020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191023M/120191023M_Closure%20Letter_02212020.pdf\n\n120191023M_Closure Letter_02212020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191023M/120191023M_Closure%20Letter_02212020_text.pdf\n\n120191023M_Notice of Amendment_12192019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191023M/120191023M_Notice%20of%20Amendment_12192019.pdf\n\n120191023M_Notice of Amendment_12192019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191023M/120191023M_Notice%20of%20Amendment_12192019_text.pdf\n\n120191023M_Operator Response to Notice_02182020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191023M/120191023M_Operator%20Response%20to%20Notice_02182020.pdf\n\n120191023M_Notice of Amendment_12192019_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nDecember 19, 2019\nMs. Michele Harradence\nVP, Gas Transmission & Midstream Operations\nTexas Eastern Transmission, LP\n5400 Westheimer Court\nHouston TX 77056\nCPF 1-2019-1023M\nDear Ms. Harradence:\nFrom August 20 - 22, 2019, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected\nTexas Eastern Transmission, LP’s (Texas Eastern) procedures for the Accident Underground\nNatural Gas Storage (UNGS) facility in Garrett County, MD.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTexas Eastern’s plans or procedures, as described below:\n1. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(e) Operators of underground gas storage facilities must establish\nand follow written procedures for operations, maintenance, and\nemergencies implementing the requirements of API RP 1170 and API\nRP 1171, as required under this section, including the effective dates as\napplicable, and incorporate such procedures into their written\nprocedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nTexas Eastern’s written procedures for implementing the requirements of API RP 1171 were\ninadequate. Specifically, Texas Eastern’s procedures did not adequately define annular gas\nthreshold levels, as required by API RP 1171, Section 9.3.2.\n\n\n\nCPF 1-2019-1023M\n2. Section 9.3.2 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\nrisk assessment.\nTexas Eastern’s method for calculating annular gas threshold levels resulted in some threshold\nlevels exceeding the MAOP of the field.\n§ 192.12 Underground natural gas storage facilities.\n(a) ….\n(e) Operators of underground gas storage facilities must establish\nand follow written procedures for operations, maintenance, and\nemergencies implementing the requirements of API RP 1170 and API\nRP 1171, as required under this section, including the effective dates as\napplicable, and incorporate such procedures into their written\nprocedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nTexas Eastern’s written procedures for implementing the requirements of API RP 1171 were\ninadequate. Specifically, Texas Eastern’s procedures did not adequately address how it would\nmonitor for the presence of annular gas, as required by API RP 1171, Section 9.3.2.\nSection 9.3.2 states in part:\nThe operator shall monitor for presence of annular gas by measuring and recording\nannular pressure and/or annular gas flow.\nTexas Eastern’s procedure for monitoring gas in an annulus open to the atmosphere required\nmeasuring the pressure buildup after a 5-minute shut-in time. Texas Eastern did not include\nsubsequent actions if gas is detected in the annulus. The process is inadequate due to the lack of\nfollow-up actions if gas is detected.\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 Enforcement\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).\n120191023M_Notice of Amendment_12192019_text Page 2 of 3\n\n\n\nCPF 1-2019-1023M\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 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 Texas Eastern Transmission, LP maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nPHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Please refer\nto CPF 1-2019-1023M on each document you submit, and whenever possible provide a signed\nPDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger\nfiles should be sent on USB flash drive accompanied by the original paper copy to the Eastern\nRegion Office.\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 Enforcement Proceedings\n120191023M_Notice of Amendment_12192019_text Page 3 of 3\n\n120191023M_Closure Letter_02212020_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nFebruary 21, 2020\nMs. Michele Harradence\nVP, Gas Transmission & Midstream Operations\nTexas Eastern Transmission, LP\n5400 Westheimer Court\nHouston TX 77056\nCPF 1-2019-1023M\nDear Ms. Harradence:\nFrom August 20 - 22, 2019, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site\npipeline safety inspection of Texas Eastern Transmission, LP's (TETLP) procedures for the\nAccident Underground Natural Gas Storage (UNGS) facility in Garrett County, MD. As a result\nof the inspection, TETLP was issued a Notice of Amendment on December 19, 2019, which\nproposed amendment of your procedures.\nTETLP submitted its amended procedures on February 18, 2020. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\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":8351}