{"operation":"document","citation":"CPF 120201006M","title":"NATURAL GAS PIPELINE CO OF AMERICA (KMI) — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-01-02","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201006m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201006m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201006m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120201006M","body":"Notice of Amendment involving NATURAL GAS PIPELINE CO OF AMERICA (KMI). PHMSA's enforcement data identifies the cited regulation as 192.12(e). The case was opened on 2020-01-02 and is reported as closed as of 2020-02-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120201006M_Closure Letter_02072020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201006M/120201006M_Closure%20Letter_02072020.pdf\n\n120201006M_Closure Letter_02072020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201006M/120201006M_Closure%20Letter_02072020_text.pdf\n\n120201006M_Notice of Amendment_01022020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201006M/120201006M_Notice%20of%20Amendment_01022020.pdf\n\n120201006M_Notice of Amendment_01022020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201006M/120201006M_Notice%20of%20Amendment_01022020_text.pdf\n\n120201006M_Operator Response to Notice_01292020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201006M/120201006M_Operator%20Response%20to%20Notice_01292020.pdf\n\n120201006M_Closure Letter_02072020_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nFebruary 7, 2020\nMr. Kenneth Grubb\nChief Operating Officer\nNatural Gas Pipeline Co of America (KMI)\n1001 Louisiana Street, Suite 1000\nHouston, TX 77002\nCPF 1-2020-1006M\nDear Mr. Grubb:\nFrom August 6 - 8, 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\nNatural Gas Pipeline Co of America’s (NGPL) Cairo Storage Fields and its Underground Gas\nStorage Facility (UNGS) Program in Columbus City, IA. As a result of the inspection, NGPL was\nissued a Notice of Amendment on January 2, 2020, which proposed amendment of your\nprocedures.\nNGPL submitted its amended procedures on or about January 30, 2020. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\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\n\n120201006M_Notice of Amendment_01022020_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJanuary 2, 2020\nMr. Kenneth Grubb\nChief Operating Officer\nNatural Gas Pipeline Co of America (KMI)\n1001 Louisiana Street, Suite 1000\nHouston, TX 77002\nCPF 1-2020-1006M\nDear Mr. Grubb:\nFrom August 6 - 8, 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\nNatural Gas Pipeline Co of America’s (NGPL) Cairo Storage Fields and its Underground Gas\nStorage Facility (UNGS) Program in Columbus City, IA.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nNGPL’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.\nNGPL’s written procedures for implementing the requirements of API RP 1171 were inadequate.\nSpecifically, NGPL failed to establish procedures to evaluate any annular gas occurrence that\n\n\n\nCPF 1-2020-1006M\nexceeds its established threshold in accordance with API RP 1171, Section 9.3.2 Well Integrity\nMonitoring.\nSection 9.3.2 states in part:\nThe operator shall monitor for presence of annular gas by measuring and recording annular\npressure and/or annular gas flow. The operator shall evaluate each annular gas occurrence\nthat exceeds operator - or regulatory-defined threshold levels determined from well\nintegrity evaluation and from risk assessment.\nAt the time of the inspection, NGPL procedures failed to address the requirement of API RP\n1171, Section 9.3.2, for evaluating each annular gas occurrence that exceeds operator defined\nthresholds. In addition, it was noted that NGPL had established thresholds that exceeded the\nMAOP of the storage field.\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).\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 30 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 Natural Gas Pipeline Co of America maintain documentation\nof the safety 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 1-2020-1006M 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.\n120201006M_Notice of Amendment_01022020_text Page 2 of 3\n\n\n\nCPF 1-2020-1006M\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\n120201006M_Notice of Amendment_01022020_text Page 3 of 3","truncated":false,"body_characters":7392}