{"operation":"document","citation":"CPF 12021012NOA","title":"TRES PALACIOS GAS STORAGE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-04-20","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021012noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021012noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021012noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021012NOA","body":"Notice of Amendment involving TRES PALACIOS GAS STORAGE LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2021-04-20 and is reported as closed as of 2021-06-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021012NOA_Closure Letter_06172021_(20-173619).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021012NOA/12021012NOA_Closure%20Letter_06172021_(20-173619).pdf\n\n12021012NOA_Closure Letter_06172021_(20-173619)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021012NOA/12021012NOA_Closure%20Letter_06172021_(20-173619)_text.pdf\n\n12021012NOA_Notice of Amendment_04202021_(20-173619).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021012NOA/12021012NOA_Notice%20of%20Amendment_04202021_(20-173619).pdf\n\n12021012NOA_Notice of Amendment_04202021_(20-173619)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021012NOA/12021012NOA_Notice%20of%20Amendment_04202021_(20-173619)_text.pdf\n\n12021012NOA_Operator Response to Notice_05032021_(20-173619).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021012NOA/12021012NOA_Operator%20Response%20to%20Notice_05032021_(20-173619).pdf\n\n12021012NOA_Notice of Amendment_04202021_(20-173619)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: Eric.Ormond@crestwoodlp.com\nApril 20, 2021\nMr. Eric Ormond\nVP, Engineering & Project Management\nTres Palacios Gas Storage LLC\n811 Main Street\nHouston, Texas 77002\nCPF 1-2021-012-NOA\nDear Mr. Ormond:\nFrom July 14-16, 2020, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nTres Palacios Gas Storage LLC’s (TPGS) procedures1 for the Tres Palacios Gas Storage facility\nin Markham, Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTPGS’s plans 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.\n1 Tres Palacios Gas Storage, LLC is a subsidiary of Crestwood Midstream Partners, LP and uses Crestwood’s\nprocedures.\n\n\n\nCPF 1-2021-012-NOA\nTPGS's written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities under §192.12(a)(3) were inadequate. Specifically, TPGS's UNGS OM did\nnot describe its operation and maintenance (O&M) processes in detail in accordance with API RP\n1170, Section 9.7.1 Procedures (Section 9.7.1).\nSection 192.12(a)(3) states in relevant part, for operators that use a solution-mined salt cavern for\nnatural gas storage, constructed on or before July 18, 2017, to meet the provisions of API RP 1170\n(incorporated by reference, see §192.7), section 9, by January 18, 2018.\nSection 9.7.1 states in relevant part:\nAll operators shall have or develop operation and maintenance (O&M) procedures. These\nprocedures should allow for the safe operation and necessary maintenance of the wellhead\nand cavern to ensure integrity. Operators should have specific procedures for caverns and\nwellheads that include routine operation and maintenance guidelines as well as workover\nand emergency procedures.\nAt the time of the inspection, TPGS's UNGS OM did not describe the O&M processes with\nspecificity. Procedures presented to PHMSA at the time only re-stated the requirements of API\nRP 1170. Therefore, TGPS’s procedures lacked details to thoroughly describe the O&M processes\nused to maintain ongoing functional integrity of the storage facility. TPGS must revise its\nprocedures to include detailed O&M procedures.\n2. § 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.\nTPGS’s written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities under § 192.12(a)(3) were inadequate. Specifically, TPGS's OM S2.29.1\nprocedures did not describe the process it uses to establish a maximum and minimum storage\noperating pressure, or its process for converting maximum and minimum pressure at a casing seat\nto a maximum and minimum wellhead pressure, in accordance with API RP 1170, Section 9.1-\nMinimum and Maximum Operating Limits (Section 9.1).\nAs noted above, § 192.12(a)(3) requires operators that use a solution-mined salt cavern for natural\ngas storage, constructed on or before July 18, 2017, to meet the provisions of API RP 1170\n(incorporated by reference, see §192.7), section 9, by January 18, 2018.\n12021012NOA_Notice of Amendment_04202021_(20-173619)_text Page 2 of 5\n\n\n\nCPF 1-2021-012-NOA\nSection 9.1 states in relevant part:\nMaximum storage operating pressures shall be established by the operator.\n…\nThe operator shall then convert the maximum and minimum pressure at the casing seat to a\nmaximum and minimum wellhead pressure if the wellhead is the monitoring point of record.\nAt the time of the inspection, TPGS's procedures restated Section 9.1 but did not describe the\nprocesses that TPGS uses to establish a maximum and minimum storage operating pressure or its\nprocess for converting casing seat pressures to wellhead pressures. TPGS must revise its\nprocedures to include its processes for complying with API RP 1170 Section 9.1, in accordance\nwith § 192.12(a)(3).\n3. § 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.\nTPGS's written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities under §192.12(a)(3) were inadequate. Specifically, TPGS does not have\ndetailed procedures to describe its evaluation process for the applicability of integrity monitoring\nmethods in accordance with API RP 1170, Section 10.4 - Review of Integrity Monitoring Methods\n(Section 10.4).\nAs noted above, § 192.12(a)(3) requires operators that use a solution-mined salt cavern for natural\ngas storage, constructed on or before July 18, 2017, to meet the provisions of API RP 1170\n(incorporated by reference, see §192.7), section 10, by January 18, 2018.\nSection 10.4 states in relevant part:\nTable 1 lists monitoring methods currently in use by salt cavern operators. Each operator\nshall evaluate these methods for applicability and inclusion in their Integrity Monitoring\nProgram. These methods are found in Annex B.\nAt the time of the inspection, TPGS's procedures did not describe the evaluation processes for\nintegrity monitoring methods in detail. Therefore, TPGS did not develop evaluation processes for\nintegrity monitoring methods as required by Section 10.4. TPGS must revise its procedures to\n12021012NOA_Notice of Amendment_04202021_(20-173619)_text Page 3 of 5\n\n\n\nCPF 1-2021-012-NOA\ninclude details on its integrity monitoring methods.\n4. § 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.\nTPGS's written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities under §192.12(a)(3) were inadequate. Specifically, TPGS's UNGS OM\nprocedures did not describe the process for Lockout and Tagout (LOTO) operations in accordance\nwith API RP 1170, Section 9.6.8 - Lockout and Tagout Systems (Section 9.6.8).\nAs stated above, § 192.12(a)(3) requires operators that use a solution-mined salt cavern for natural\ngas storage, constructed on or before July 18, 2017, to meet the provisions of API RP 1170\n(incorporated by reference, see §192.7), section 9, by January 18, 2018.\nSection 9.6.8 states in part:\nLockout and tagout (LOTO) systems shall be used at storage facilities to protect workers\nfrom hazardous energy sources. A LOTO procedure shall be developed for each cavern\nwellhead to allow for calibration, maintenance and workovers.\nAt the time of the inspection, TPGS's procedures did not include LOTO procedures, as required\nby Section 9.6.8. TPGS must amend its procedures to include LOTO procedures.\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).\n12021012NOA_Notice of Amendment_04202021_(20-173619)_text Page 4 of 5\n\n\n\nCPF 1-2021-012-NOA\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 Tres Palacios Gas Storage, 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 1-2021-012-NOA 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\n12021012NOA_Notice of Amendment_04202021_(20-173619)_text Page 5 of 5\n\n12021012NOA_Closure Letter_06172021_(20-173619)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJune 17, 2021\nMr. Eric Ormond\nVP, Engineering & Project Management\nTres Palacios Gas Storage LLC\n811 Main Street\nHouston, Texas 77002\nCPF 1-2021-012-NOA\nDear Mr. Ormond:\nFrom July 14-16, 2020, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nTres Palacios Gas Storage LLC’s (TPGS) procedures1 for the Tres Palacios Gas Storage facility\nin Markham, Texas. As a result of the inspection, TPGS was issued a Notice of Amendment on\nApril 20, 2021, which proposed amendment of your procedures.\nTPGS submitted its amended procedures on May 3, 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\n1 Tres Palacios Gas Storage, LLC is a subsidiary of Crestwood Midstream Partners, LP and uses Crestwood’s\nprocedures.","truncated":false,"body_characters":14768}