{"operation":"document","citation":"CPF 12022005WL","title":"AMEREN ILLINOIS COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-02-08","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022005wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022005wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022005wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022005WL","body":"Warning Letter involving AMEREN ILLINOIS COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(2). The case was opened on 2022-02-08 and is reported as closed as of 2022-02-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022005WL_Warning Letter_02082022_(21-220265).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022005WL/12022005WL_Warning%20Letter_02082022_(21-220265).pdf\n\n12022005WL_Warning Letter_02082022_(21-220265)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022005WL/12022005WL_Warning%20Letter_02082022_(21-220265)_text.pdf\n\n12022005WL_Warning Letter_02082022_(21-220265)_text.pdf\n\nCPF 1-2022-005-WL\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nFebruary 8, 2022\nMr. Mark Richard\nPresident and Chief Executive Officer\nAmeren Illinois Company\n10 Executive Drive\nCollinsville, Illinois 62234\nCPF 1-2022-005-WL\nDear Mr. Richard:\nFrom August 24 to 27, 2021, the Illinois Department of Natural Resources, Office of Oil and Gas\nResource Management (IDNR) acting as a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nAmeren Illinois Company’s (Ameren III) Sciota Underground Natural Gas Storage Facility in Sciota,\nIllinois.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable\nviolation is:\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 before\nJuly 18, 2017, must meet the provisions of API RP 1171 (incorporated by\nreference, see §192.7), sections 8, 9, 10, and 11, and paragraph (c) of this\nsection, by January 18, 2018, and must meet all provisions of paragraph\n(d) of this section by March 13, 2021.\nAmeren III failed to meet the provisions of API RP 1171, Section 8. Specifically, Ameren III failed to\ninclude certain 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).\n12022005WL_Warning Letter_02082022_(21-220265)_text Page 1 of 2\n\n\n\nCPF 1-2022-005-WL\nSection 8.4.2 states in part that “The operator shall evaluate the potential threats and hazards impacting\nstorage wells and reservoirs.”\nDuring the inspection, Ameren III reported that potential threats and hazards impacting the reservoir\nhad not been incorporated into the risk management model. Specifically, third party drilling activities,\nseismic activity, and inventory analysis were not included in the risk analysis.\nTherefore, Ameren III failed to meet the provisions of Section 8.4.2.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related\nseries of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the\nmaximum penalty may not exceed $222,504 per violation per day the violation persists, up to a\nmaximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31,\n2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per violation per\nday the violation persists, up to a maximum of $2,186,465 for a related series of violations. For\nviolation occurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty\nmay not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679.\nFor violation occurring on or after November 2, 2015 and before November 27, 2018, the maximum\npenalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed\n$2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time. We advise\nyou to correct the item identified in this letter. Failure to do so will result in Ameren Illinois Company\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF\n1-2022-005-WL. Be advised that all material you submit in response to this enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive material\nqualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n12022005WL_Warning Letter_02082022_(21-220265)_text Page 2 of 2","truncated":false,"body_characters":5232}