{"operation":"document","citation":"CPF 12021016NOA","title":"TALLGRASS INTERSTATE GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-04-23","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c), 192.12(d)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021016noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021016noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021016noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021016NOA","body":"Notice of Amendment involving TALLGRASS INTERSTATE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.12(c),  192.12(d)(4). The case was opened on 2021-04-23 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\n12021016NOA_Closure Letter_06172021_(20-173840).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021016NOA/12021016NOA_Closure%20Letter_06172021_(20-173840).pdf\n\n12021016NOA_Closure Letter_06172021_(20-173840)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021016NOA/12021016NOA_Closure%20Letter_06172021_(20-173840)_text.pdf\n\n12021016NOA_Notice of Amendment_04232021_(20-173840).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021016NOA/12021016NOA_Notice%20of%20Amendment_04232021_(20-173840).pdf\n\n12021016NOA_Notice of Amendment_04232021_(20-173840)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021016NOA/12021016NOA_Notice%20of%20Amendment_04232021_(20-173840)_text.pdf\n\n12021016NOA_Operator Response to Notice_05212021_(20-173840).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021016NOA/12021016NOA_Operator%20Response%20to%20Notice_05212021_(20-173840).pdf\n\n12021016NOA_Closure Letter_06172021_(20-173840)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJune 17, 2021\nMr. Mick Rafter\nSr. VP Engineering & Operations\nTallgrass Interstate Gas Transmission, LLC\n370 Van Gordon St\nLakewood, CO 80228\nCPF 1-2021-016-NOA\nDear Mr. Rafter:\nOn July 21-23 and August 10, 2020, representatives from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted\nan underground natural gas storage inspection of Tallgrass Interstate Gas Transmission, LLC’s\n(Tallgrass) procedures in Cheyenne County, Nebraska. As a result of the inspection, Tallgrass was\nissued a Notice of Amendment on April 23, 2021, which proposed amendment of your procedures.\nTallgrass submitted its amended procedures on May 21, 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\n\n12021016NOA_Notice of Amendment_04232021_(20-173840)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nApril 23, 2021\nMr. Mick Rafter\nSr. VP Engineering & Operations\nTallgrass Interstate Gas Transmission, LLC\n370 Van Gordon St\nLakewood, CO 80228\nCPF 1-2021-016-NOA\nDear Mr. Rafter:\nOn July 21-23, 2020 and August 10, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected Tallgrass Interstate Gas Transmission, LLC’s (Tallgrass) procedures for the\nHuntsman Gas Storage field in Cheyenne County, Nebraska.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTallgrass’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.\n\n\n\nCPF 1-2021-016-NOA\nTallgrass’s written procedures for conducting operations, maintenance, and emergency\npreparedness and response activities under §192.12(b)1 were inadequate. Specifically, Tallgrass’s\nprocedures failed to establish how frequently well integrity evaluation data from third-party well\nowner/operators would be requested in accordance with API RP 1171, Section 9.3.1 (Section\n9.3.1).\nSection 9.3.1 states in part:\nThe operator shall request well integrity evaluation data from third-party well\nowner/operators following the frequency established using conclusions from the risk\nassessment.\nDuring the inspection, Tallgrass reported that it had not established a frequency for requesting well\nintegrity evaluation data from third-party well owner/operators.\nTherefore, Tallgrass’s written procedures required by § 192.12(c) were inadequate. Tallgrass must\nrevise its procedures to include how frequently it will request well integrity evaluation data from\nthird-party well owner/operators in accordance with Section 9.3.1.\n2. § 192.12 Underground natural gas storage facilities.\n(a) …\n(d) Integrity management program—\n(1) …\n(4) Integrity management procedures and recordkeeping. Each\nUNGSF operator must establish and follow written procedures to carry\nout its integrity management program under API RP 1171\n(incorporated by reference, see § 192.7), section 8 (\"Risk Management\nfor Gas Storage Operations\"), and this paragraph (d). The operator\nmust also maintain, for the useful life of the UNGSF, records that\ndemonstrate compliance with the requirements of this paragraph (d).\nThis includes records developed and used in support of any\nidentification, calculation, amendment, modification, justification,\ndeviation, and determination made, and any action taken to implement\nand evaluate any integrity management program element.\nTallgrass’s written procedures for carrying out its integrity management program under API RP\n1171, Section 8 were inadequate. Specifically, Tallgrass did not have a procedure to assess threat\nand hazard interaction in accordance with API RP 1171, Section 8.3.2 (Section 8.3.2).\n1 §192.12 Underground natural gas storage facilities.\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) Each UNGSF that uses a depleted hydrocarbon reservoir or an aquifer reservoir for natural gas storage and was\nconstructed after July 18, 2017, must meet all provisions of API RP 1171 (incorporated by reference, see §192.7),\nand paragraphs (c) and (d) of this section, prior to commencing operations.\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an aquifer reservoir for natural gas storage and was\nconstructed on or before July 18, 2017, must meet the provisions of API RP 1171 (incorporated by reference, see\n§192.7), sections 8, 9, 10, and 11, and paragraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\n12021016NOA_Notice of Amendment_04232021_(20-173840)_text Page 2 of 4\n\n\n\nCPF 1-2021-016-NOA\nSection 8.3.2 states in part:\nThe operator shall use available information such as performance data collected\nthrough the field history, operations and maintenance (O&M) activities, geotechnical\ndata such as well logs, engineering data, and completion reports to determine\nsusceptibility to threat and hazard-related events and to assess threat and hazard\ninteraction.\nDuring the inspection, Tallgrass reported that they did not have a procedure for assessing threats\nand hazard interaction.\nTherefore, Tallgrass’s written procedures required by § 192.12(d)(4) were inadequate. Tallgrass\nmust revise its procedures to include how it will assess threat and hazard interaction in accordance\nwith Section 8.3.2.\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 Tallgrass Interstate Gas Transmission, LLC maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough,\nDirector, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628.\nPlease refer to CPF 1-2021-016-NOA on each document you submit, and whenever possible\nprovide a signed PDF copy in electronic format. Smaller files may be emailed to\nrobert.burrough@dot.gov. Larger files should be sent on USB flash drive accompanied by the\noriginal paper copy to the Eastern Region Office.\n12021016NOA_Notice of Amendment_04232021_(20-173840)_text Page 3 of 4\n\n\n\nCPF 1-2021-016-NOA\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\n12021016NOA_Notice of Amendment_04232021_(20-173840)_text Page 4 of 4","truncated":false,"body_characters":10674}