{"operation":"document","citation":"CPF 12021015WL","title":"TALLGRASS INTERSTATE GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-03-05","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021015wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021015wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021015wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021015WL","body":"Warning Letter involving TALLGRASS INTERSTATE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(2). The case was opened on 2021-03-05 and is reported as closed as of 2021-03-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021015WL_Warning Letter_03052021_(20-173840).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021015WL/12021015WL_Warning%20Letter_03052021_(20-173840).pdf\n\n12021015WL_Warning Letter_03052021_(20-173840)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021015WL/12021015WL_Warning%20Letter_03052021_(20-173840)_text.pdf\n\n12021015WL_Warning Letter_03052021_(20-173840)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: mick.rafter@tallgrassenergylp.com\nMarch 5, 2021\nMick Rafter\nSr. VP Engineering & Operations\nTallgrass Interstate Gas Transmission, LLC\n370 Van Gordon St\nLakewood, CO 80228\nCPF 1-2021-015-WL\nDear Mr. Rafter:\nOn July 21-23 and August 10, 2020, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected Tallgrass Interstate Gas Transmission, LLC’s (Tallgrass) Huntsman Gas Storage field\nin Cheyenne County, Nebraska.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. §192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) …\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see § 192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nTallgrass failed to meet the provisions of API RP 1171, Section 8. Specifically, Tallgrass failed to\n\n\n\nCPF 1-2021-015-WL\ninclude potential threats and hazards impacting the reservoir in its risk management model in\naccordance with API RP 1171, Section 8.4.2 (Section 8.4.2).\nSection 8.4.2 states in part, “The operator shall evaluate the potential threats and hazards impacting\nstorage wells and reservoirs.”\nDuring the inspection, Tallgrass reported that potential threats and hazards impacting the reservoir\nhad not been incorporated into the risk management model. Tallgrass stated that they planned to\nadd threats to the reservoir from plugged and abandoned wells and 3rd party wells within the\nreservoir boundary to their risk model in the fourth quarter of 2020. Therefore, Tallgrass failed to\nmeet the provisions of Section 8.4.2.\n2. §192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) …\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see § 192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nTallgrass failed to meet the provisions of API RP 1171, Section 11. Specifically, Tallgrass failed\nto notify and train operating personnel whenever changes were made to the operating procedures\nin accordance with API RP 1171, Section 11.12.2 (Section 11.12.2).\nSection 11.12.2 states in part:\nWhenever changes are made to the operating procedures specified in 11.3, operating\npersonnel shall be notified and trained as necessary in the changes and training\ndocumented before operating storage wells and reservoirs.\nDuring the inspection, which occurred the week of July 21, 2020, Tallgrass was not able to provide\nrecords showing that operating personnel were notified and trained on the changes to operating\nprocedures resulting from its new Gas Storage Integrity Monitoring Plan (GSIMP). It was also\nnoted that the GSIMP presented was dated 08-01-2020, but Tallgrass stated that it was in effect at\nthe time of the inspection. Therefore, Tallgrass failed to meet the provisions of Section 11.12.2.\n3. §192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) …\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see § 192.7), sections 8, 9, 10, and 11, and\n12021015WL_Warning Letter_03052021_(20-173840)_text Page 2 of 4\n\n\n\nCPF 1-2021-015-WL\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nTallgrass failed to meet the provisions of API RP 1171, Section 8. Specifically, Tallgrass failed to\nreview its risk assessment results in accordance with API RP 1171, Section 8.5.2 (Section 8.5.2).\nSection 8.5.2 states in part:\nThe operator shall review the results of the risk assessment to determine whether the\nrisk assessment, resulting prioritization, or ranking represents its facilities and\ncharacterizes the risks.\nDuring the inspection, Tallgrass was not able to provide records that the risk assessment results\nwere reviewed to determine whether the risk assessment, resulting prioritization, or ranking\nrepresented its facilities and characterized the risks. Therefore, Tallgrass failed to meet the\nprovisions of Section 8.5.2.\n4. §192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) …\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see § 192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nTallgrass failed to meet the provisions of API RP 1171, Section 9. Specifically, Tallgrass failed to\nevaluate the mechanical integrity of each active third-party well that penetrated the storage\nreservoir and buffer zone or areas influenced by storage operations in accordance with API RP\n1171, Section 9.3.1 (Section 9.3.1).\nSection 9.3.1 states in part:\nThe operator shall evaluate the mechanical integrity of each active well, including\neach third-party well, that penetrates the storage reservoir and buffer zone or areas\ninfluenced by storage operations.\nDuring the inspection, Tallgrass reported that they had not completed the evaluation of each active\nthird-party well that penetrated its storage reservoir and buffer zone or areas influenced by its\nstorage operations. Therefore, Tallgrass failed to meet the provisions of Section 9.3.1.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related\nseries of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021,\nthe maximum penalty may not exceed $218,647 per violation per day the violation persists, up to\n12021015WL_Warning Letter_03052021_(20-173840)_text Page 3 of 4\n\n\n\nCPF 1-2021-015-WL\na maximum of $2,186,465 for a related series of violations. For violation occurring on or after\nNovember 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per\nviolation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on\nor after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed\n$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item(s) identified in this letter. Failure to do so will result in\nin Tallgrass Interstate Gas Transmission, LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2021-015-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n12021015WL_Warning Letter_03052021_(20-173840)_text Page 4 of 4","truncated":false,"body_characters":9241}