{"operation":"document","citation":"CPF 120201009M","title":"TEXAS GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-03-27","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201009m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201009m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201009m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120201009M","body":"Notice of Amendment involving TEXAS GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(e). The case was opened on 2020-03-27 and is reported as closed as of 2020-05-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120201009M_Closure Letter_05072020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201009M/120201009M_Closure%20Letter_05072020.pdf\n\n120201009M_Closure Letter_05072020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201009M/120201009M_Closure%20Letter_05072020_text.pdf\n\n120201009M_Notice of Amendment_03272020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201009M/120201009M_Notice%20of%20Amendment_03272020.pdf\n\n120201009M_Notice of Amendment_03272020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201009M/120201009M_Notice%20of%20Amendment_03272020_text.pdf\n\n120201009M_Operator Response to Notice_04232020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201009M/120201009M_Operator%20Response%20to%20Notice_04232020.pdf\n\n120201009M_Notice of Amendment_03272020_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nMarch 27, 2020\nMr. Richard Keyser\nSenior Vice President of Operations\nTexas Gas Transmission, LLC\n9 Greenway Plaza, Suite 2800\nHouston, TX 77046\nCPF 1-2020-1009M\nDear Mr. Keyser:\nFrom March 25 – 28, 2019, June 3 – 6, 2019, and August 27 – 29, 2019, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of\n49 United States Code (U.S.C.), inspected Texas Gas Transmission, LLC’s (TGT) underground\nnatural gas storage field records and procedures for the Graham Lake, Leesville, Midland, and\nWest Greenville storage fields in Muhlenberg County, Kentucky and Lawrence County, Indiana.\nOn the basis of the inspections, PHMSA has identified the apparent inadequacies found within\nTGT’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 § 192.605.1\n1 The final rule, Pipeline Safety: Safety of Underground Natural Gas Storage Facilities, 85 FR 8104 (February 12,\n2020), revised § 192.12. The requirement cited in this Notice of Amendment is still present but is now codified in\n§ 192.12(c).\n\n\n\nCPF 1-2020-1009M\nTGT’s written procedures for implementing the requirements of API RP 1171 were inadequate.\nSpecifically, TGT’s procedures did not address how it would assess threat and hazard interaction\nin their Risk Model, as required by API RP 1171, Section 8.3.2 Data Sources (Section 8.3.2).\nSection 8.3.2 states:\nThe operator shall use available information such as performance data collected\nthrough the field history, operations and maintenance (O&M) activities,\ngeotechnical data such as well logs, engineering data, and completion reports to\ndetermine susceptibility to threat and hazard-related events and to assess threat and\nhazard interaction.\nAt the time of the inspections, TGT’s procedures failed to demonstrate how the threat and hazard\ninteraction requirement was addressed in their Risk Management Model as required by Section\n8.3.2.\n2. § 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.\nTGT’s written procedures for implementing the requirements of API RP 1171 were inadequate.\nSpecifically, TGT’s procedures did not address how the effectiveness of their Risk Management\nplan would be determined, as required by API RP 1171, Section 8.7.1 Periodic Assessment and\nReview (Section 8.7.1).\nSection 8.7.1 states in part:\nThe operator shall assess the effectiveness of risk monitoring and risk management\nprograms and maintain a continual review and improvement cycle in risk\nmanagement activities to provide functional integrity of the storage operation. The\ninterval of review and reassessment should be short enough to identify operational\nand monitoring trends and measure the effectiveness of P&M measures, but long\nenough that the data and information that can be brought into the analysis are\nmeaningful.\nAt the time of the inspections, TGT’s procedures failed to address how the effectiveness of their\nRisk Management plan would be determined in accordance with Section 8.7.1.\n3. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(e) Operators of underground gas storage facilities must establish\n120201009M_Notice of Amendment_03272020_text Page 2 of 5\n\n\n\nCPF 1-2020-1009M\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.\nTGT’s written procedures for implementing the requirements of API RP 1171 were inadequate.\nSpecifically, TGT’s procedures failed to address annular gas monitoring requirements for its\nmonitor wells that do not have any taps on their annulus. Furthermore, TGT also failed to establish\nprocedures to evaluate any occurrence of annular gas that exceeds the established threshold level,\nas required by API RP 1171, Section 9.3.2 Well Integrity Monitoring (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. The operator shall evaluate each annular\ngas occurrence that exceeds operator - or regulatory-defined threshold levels\ndetermined from well integrity evaluation and from risk assessment.\nAt the time of the inspections, TGT procedures failed to address the requirements of API RP 1171,\nSection 9.3.2. TGT could not provide a procedure to evaluate annulus pressure or flow for wells\nin multiple storages that do not have any annulus taps. TGT also could not demonstrate that they\nhad procedures to address any exceedance of threshold pressure on the annulus. Finally, TGT\ncould not produce documentation showing they had evaluated the one exceedance of their defined\nthresholds at the Midland Storage Facility.\n4. § 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.\nTGT’s written procedures for implementing the requirements of API RP 1171 were inadequate.\nSpecifically, TGT failed to establish procedures that required data gathering of pressures and\nvolumes to determine the integrity of the Midland and Leesville storage fields for 2018, in\naccordance with Section 8.3.2.\nSection 8.3.2 Data Sources states in part:\nThe operator shall use available information such as performance data collected\nthrough the field history, operations and maintenance (O&M) activities,\ngeotechnical data such as well logs, engineering data, and completion reports to\n120201009M_Notice of Amendment_03272020_text Page 3 of 5\n\n\n\nCPF 1-2020-1009M\n5. determine susceptibility to threat and hazard-related events and to assess threat and\nhazard interaction.\nAt the time of the inspection, TGT had not established adequate procedures regarding data\ngathering for the Midland and Leesville Storages to prove adequacy of the integrity of the storage\nfacility for that year. The wells in these two storages did not have taps that would allow the\ngathering of the required information. TGT had not develop a procedure to remedy this issue, nor\nhad it developed additional Preventative and Mitigative (P&M) measures to ensure well integrity\nuntil taps are available.\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.\nTGT’s written procedures for implementing the requirements of API RP 1171 were inadequate.\nSpecifically, TGT’s Storage Integrity Program procedures did not include a process for data\ngathering and assessing plugged and abandoned third-party wells in accordance with Section 8.3.2.\nAt the time of the inspection, TGT’s written Storage Integrity Program procedures failed to address\ndata gathering and assessing plugged and abandoned third-party wells.\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\n120201009M_Notice of Amendment_03272020_text Page 4 of 5\n\n\n\nCPF 1-2020-1009M\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 Gas Transmission, LLC 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 1-2020-1009M 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\n120201009M_Notice of Amendment_03272020_text Page 5 of 5\n\n120201009M_Closure Letter_05072020_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMay 7, 2020\nMr. Richard Keyser\nSenior Vice President of Operations\nTexas Gas Transmission, LLC\n9 Greenway Plaza, Suite 2800\nHouston, TX 77046\nCPF 1-2020-1009M\nDear Mr. Keyser:\nFrom March 25 - 28, 2019, June 3 – 6, 2019, and August 27 - 29, 2019, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of\n49 United States Code (U.S.C.), inspected Texas Gas Transmission, LLC’s (TGT) underground\nnatural gas storage field records and procedures for the Graham Lake, Leesville, Midland, and\nWest Greenville storage fields in Muhlenberg County, Kentucky and Lawrence County, Indiana.\nAs a result of the inspection, TGT was issued a Notice of Amendment on March 27, 2020, which\nproposed amendment of your procedures.\nTGT submitted its amended procedures on or about April 23, 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":13837}