# ANR PIPELINE CO — Warning Letter

- **operation:** document
- **citation:** CPF 120201004W
- **title:** ANR PIPELINE CO — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2020-01-02
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.12(d), 192.12(e).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-120201004w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120201004w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120201004w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120201004W
**body:**

Warning Letter involving ANR PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 192.12(d),  192.12(e). The case was opened on 2020-01-02 and is reported as closed as of 2020-01-02. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120201004W_Warning Letter_01022020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201004W/120201004W_Warning%20Letter_01022020.pdf

120201004W_Warning Letter_01022020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201004W/120201004W_Warning%20Letter_01022020_text.pdf

120201004W_Warning Letter_01022020_text.pdf

WARNING LETTER
OVERNIGHT EXPRESS DELIVERY
January 2, 2020
Mr. Stan Chapman
Senior Vice President
ANR Pipeline Co.
700 Louisiana St.
Houston, TX. 77002
CPF 1-2020-1004W
Dear Mr. Chapman:
During the weeks of March 11 – March 15 and August 19 – August 22, 2019, representatives of
the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601
of 49 United States Code (U.S.C.), inspected ANR Pipeline Co’s (ANR) Reed City, Austin and
Loreed Underground Natural Gas facilities in Michigan.
As a result of the inspections, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:
1. § 192.12 Underground natural gas storage facilities.
(a) …
(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.



CPF 1-2020-1004W
ANR failed to meet the monitoring requirements of API RP 1171, Section 9. Specifically, ANR
failed to evaluate each annular gas occurrence that exceeded operator-defined threshold levels
determined from well integrity evaluation and from risk assessment, as directed by API RP 1171,
Section 9.3.2.
Section 9.3.2 of API RP 1171, Well Integrity Monitoring, states in part:
The operator shall evaluate each annular gas occurrence that exceeds operator- or
regulatory-defined threshold levels determined from well integrity evaluation and from risk
assessment.
ANR’s procedure TEP-PR-REST-G, Well Annulus Pressure Analysis Section 2.1, states that every
well shall have a calculated Maximum Allowable Annulus Surface Pressure (MAASP).
During the inspection, the PHMSA inspector reviewed records for MAASP cacluations. The
records demonstrated that not all wells had MAASP cacluations completed, and therefore not all
annular gas occurences were evaluated based on an operator-defined threshold.
2. § 192.12 Underground natural gas storage facilities.
(a) …
(e) Operators of underground gas storage facilities must establish
and follow written procedures for operations, maintenance, and
emergencies implementing the requirements of API RP 1170 and API
RP 1171, as required under this section, including the effective dates as
applicable, and incorporate such procedures into their written
procedures for operations, maintenance, and emergencies established
pursuant to § 192.605.
ANR failed to follow its written procedures for operations, maintenance, and emergencies
implementing the requirements of API RP 1170 and API RP 1171. Specifically, ANR failed to
inspect the mastervalves on an annual basis as required in its procedure TEP-PR-WESTS-G,
Wellheads and Wellhead Valves Monitoring, Testing, and Maintenance.
ANR’s procedure TEP-PR-WESTS-G, Wellheads and Wellhead Valves Monitoring, Testing, and
Maintenance states that master valves will be inspected and tested annually.
During the field inspection at Loreed, the PHMSA inspectors reviewed valve inspection records
for the wells at the Loreed storage facilities. Records indicated that in 2018, not all wells had been
function tested. The records indicated approximately 107 of the 198 wells had been inspected
during 2018.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related
series of violations. For violation occurring on or after November 27, 2018 and before July 31,
2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum
penalty not to exceed $2,132,679. 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
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CPF 1-2020-1004W
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 ANR Pipeline Co. being subject to
additional enforcement action.
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).
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 1-2020-1004W 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 a 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
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