CPF 12021038NOA
CPF 12021038NOA
party submissionOfficial PDF12021038NOA_Operator Response to Notice_05262021_(20-185140).pdf#
12021038NOA_Closure Letter_07092021_(20-185140)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: shawn.patterson@southernstar.com July 9, 2021 Mr. Shawn Patterson VP & Chief Operations Officer Southern Star Central Gas Pipeline, Inc. 4700 State Route 56 P.O. Box 20010 Owensboro, Kentucky 42304-0010 CPF 1-2021-038-NOA Dear Mr. Patterson: On July 1, 2020, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Southern Star Central Gas Pipeline, Inc’s procedures in Blackwell, Oklahoma. As a result of the inspection, Southern Star Central Gas Pipeline, Inc. was issued a Notice of Amendment on May 20, 2021, which proposed amendment of your procedures. Southern Star Central Gas Pipeline, Inc submitted its amended procedures on May 26, 2021. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#
12021038NOA_Notice of Amendment_05202021_(20-185140)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY May 20, 2021 Mr. Jimmy Staton President and CEO Southern Star Central Gas Pipeline, Inc 4700 State Route 56 BOX 20010 Owensboro, KY 42301 CPF 1-2021-038-NOA Dear Mr. Staton: On June 30, 2020, an Incident occurred at Southern Star Central Gas Pipeline, Inc’s (SSCGP) Blackwell Storage Field that resulted in the hospitalization of an employee due to an injury. The Well 30 Incident (Incident) occurred around 12:00 PM during workover operations to isolate a well that had annular pressures that exceeded operator’s thresholds. SSCGP was in the process of relieving the pressure in the wellbore when an employee supervising the operations was struck on the back of the head by equipment that was part of the apparatus used to relieve pressure from the wellbore. The employee was administered first aid while an ambulance was dispatched and was later admitted for head injuries. On July 1, 2020, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code investigated the Incident and reviewed procedures that were in use at the time of the Incident in Blackwell, Oklahoma. On the basis of the investigation, PHMSA has identified the apparent inadequacy found within SSCGP’s plans or procedures, as described below: 1. § 192.12 Underground natural gas storage facilities. (a) … (c) Procedural manuals. Each operator of a UNGSF must prepare and follow for each facility one or more manuals of written procedures for conducting operations, maintenance, and emergency preparedness and response activities under paragraphs (a) and (b) of this section.#
12021038NOA_Notice of Amendment_05202021_(20-185140)_text.pdf, page 2CPF 1-2021-038-NOA Each operator must keep records necessary to administer such procedures and review and update these manuals at intervals not exceeding 15 months, but at least once each calendar year. Each operator must keep the appropriate parts of these manuals accessible at locations where UNGSF work is being performed. Each operator must have written procedures in place before commencing operations or beginning an activity not yet implemented. SSCGP’s written procedures for conducting operations, maintenance, and emergency preparedness and response activities under § 192.12(b) were inadequate. Specifically, SSCGP’s procedures did not describe the process used for workover operations in accordance with API RP 1171, Section 11.2 Procedures (Section 11.2). Section 11.2 states in part: The operator shall develop and follow procedures for the construction, operation, and maintenance of natural gas storage wells and reservoirs to establish and maintain functional integrity. At the time of the investigation, SSCGP’s procedures did not state the precautions that should be taken when using equipment that has not been approved for usage during workover operations. Specifically, SSCGP’s procedures did not have provisions preventing the use of equipment that can cause an uncontrolled release of gas. Therefore, SSCGP’s written procedures required by § 192.12(c) were inadequate. SSCGP must revise its written procedures to address this deficiency. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans 12021038NOA_Notice of Amendment_05202021_(20-185140)_text Page 2 of 3#
12021038NOA_Notice of Amendment_05202021_(20-185140)_text.pdf, page 3CPF 1-2021-038-NOA or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Southern Star Central Gas Pipeline, Inc maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF 1-2021-038-NOA and, for each document you submit, please provide a copy in electronic format whenever possible. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings 12021038NOA_Notice of Amendment_05202021_(20-185140)_text Page 3 of 3#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.