{"operation":"document","citation":"CPF 12021006NOA","title":"GOLDEN TRIANGLE STORAGE, INC. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-03-11","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021006noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021006noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021006noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021006NOA","body":"Notice of Amendment involving GOLDEN TRIANGLE STORAGE, INC.. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2021-03-11 and is reported as closed as of 2021-04-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021006NOA_Closure Letter_04162021_(20-173138).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021006NOA/12021006NOA_Closure%20Letter_04162021_(20-173138).pdf\n\n12021006NOA_Closure Letter_04162021_(20-173138)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021006NOA/12021006NOA_Closure%20Letter_04162021_(20-173138)_text.pdf\n\n12021006NOA_Notice of Amendment_03112021_(20-173138).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021006NOA/12021006NOA_Notice%20of%20Amendment_03112021_(20-173138).pdf\n\n12021006NOA_Notice of Amendment_03112021_(20-173138)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021006NOA/12021006NOA_Notice%20of%20Amendment_03112021_(20-173138)_text.pdf\n\n12021006NOA_Operator Response to Notice_04092021_(20-173138).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021006NOA/12021006NOA_Operator%20Response%20to%20Notice_04092021_(20-173138).pdf\n\n12021006NOA_Notice of Amendment_03112021_(20-173138)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nMarch 11, 2021\nMr. Jack Sutton\nSVP Operations Services\nGolden Triangle Storage, Inc.\n10 Peachtree Place Ne\nAtlanta, Georgia 30309\nCPF 1-2021-006-NOA\nDear Mr. Sutton:\nOn March 17 and 18, 2020, and October 14, 2020, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected Golden Triangle Storage, Inc.’s (GTS) procedures for Underground Natural\nGas Storage in Jefferson County, Texas. GTS is a wholly owned subsidiary of Southern Company\nGas (SCG).\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within GTS’\nplans or procedures, as described below:\n1. § 192.12 - Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\n\n\n\nCPF 1-2021-006-NOA\nGTS’ written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities under § 192.12(b)(2) were inadequate. Specifically, GTS’ Operations\nProcedure Manual (OPM) lacked sufficient details for the operation of underground natural gas\nstorage fields with regard to reporting requirements in 49 CFR Part 191. GTS referenced that the\nreporting requirements were included in SCG’s OPM.\nDuring the inspection, the PHMSA inspection team reviewed SCG’s OPM. The manual included\nreporting requirements. The inspection team identified the following elements of the plan, related\nto reporting requirements, that were inadequate:\n SCG OPM, Div II, Section 5.1.1 defined incidents but did not include Underground\nNatural Gas Storage Facilities (UNGSF) in the definition. (§ 191.3)\n SCG OPM, Div II, Section 5.8.1 contained procedures for filing annual reports that did\nnot include UNGSF or identified the correct form. (§ 191.17)\n SCG OPM, Div I, Section 1.3 contained procedures for obtaining an Operator\nIdentification Number (OPID) and for notification of changes, but failed to include\nspecific language for UNGSFs in those procedures. (§ 191.22)\n SCG OPM Div II, Section 5.6 did not address safety related conditions for UNGSFs.\n(§ 191.23)\nTherefore, GTS’ written procedures were inadequate regarding various reporting requirements\nfound in Part 191. GTS must revise its OPM to address the deficiencies in reporting procedures\noutlined above.\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.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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\n12021006NOA_Notice of Amendment_03112021_(20-173138)_text Page 2 of 3\n\n\n\nCPF 1-2021-006-NOA\naction will be closed.\nIt is requested (not mandated) that Golden Triangle Storage, Inc. 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,\nEastern Region, Pipeline and Hazardous Materials Safety Administration, 840 Bear Tavern Road,\nSuite 300, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF\n1-2021-006-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should\nbe sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12021006NOA_Notice of Amendment_03112021_(20-173138)_text Page 3 of 3\n\n12021006NOA_Closure Letter_04162021_(20-173138)_text.pdf\n\nVIA ELECTRONIC MAIL TO: jsutton@southernco.com\nApril 16, 2021\nMr. Jack Sutton\nSVP Operations Services\nGolden Triangle Storage, Inc.\n10 Peachtree Place Ne\nAtlanta, Georgia 30309\nCPF 1-2021-006-NOA\nDear Mr. Sutton:\nOn March 17 and 18, 2020, and October 14, 2020, representatives from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Golden Triangle Storage, Inc.’s (GTS)\nprocedures in Jefferson County, Texas. As a result of the inspection, GTS was issued a Notice of\nAmendment on March 11, 2021, which proposed amendment of your procedures.\nGTS submitted its amended procedures on April 9, 2021. 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":8349}