TRUNKLINE GAS CO — Notice of Amendment

party submissionOfficial PDF12022007NOA_Operator Response to Notice_02242022_(21-200490).pdf#

12022007NOA_Notice of Amendment_01212022_(21-200490)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY January 21, 2022 Mr. Matt Ramsey President and Chief Executive Officer Trunkline Gas Company 8111 Westchester Drive Dallas, Texas 75225 CPF 1-2022-007-NOA Dear Mr. Ramsey: From June 15, 2021 through June 17, 2021 and on June 24, 2021, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Trunkline Gas Company’s (TGC) procedures for its Epps Storage Field in West Carroll County, Louisiana. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within TGC’s 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. 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.#

12022007NOA_Notice of Amendment_01212022_(21-200490)_text.pdf, page 2CPF 1-2022-007-NOA TGC’s written procedures for conducting operations and maintenance activities were inadequate to ensure safe operation of a pipeline facility. Specifically, TGC’s written procedures did not specify that its operations & maintenance manuals would be reviewed and updated at intervals not to exceed 15 months. During the inspection, PHMSA reviewed TGC’s UNGS O&M Reservoir Plan. Although TGC’s procedures required an annual review of the O&M manuals, the procedures did not specify that the review interval would not exceed 15 months, but at least once each calendar year, in accordance with § 192.12(c). Therefore, TGC’s written procedures required by § 192.12(c) were inadequate. TGC must revise its procedures to address the review frequency of its O&M manuals. 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 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 Trunkline Gas Company 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 1-2022-007-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 12022007NOA_Notice of Amendment_01212022_(21-200490)_text Page 2 of 3#

12022007NOA_Notice of Amendment_01212022_(21-200490)_text.pdf, page 3CPF 1-2022-007-NOA 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 12022007NOA_Notice of Amendment_01212022_(21-200490)_text Page 3 of 3#

12022007NOA_Closure Letter_03152022_(21-200490)_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY March 15, 2022 Mr. Matt Ramsey President and Chief Executive Officer Trunkline Gas Company 8111 Westchester Drive Dallas, Texas 75225 CPF 1-2022-007-NOA Dear Mr. Ramsey: From June 15, 2021 through June 17, 2021 and on June 24, 2021, representatives from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an underground natural gas storage inspection of Trunkline Gas Company’s (TGC) procedures in West Carroll County, Louisiana. As a result of the inspection, TGC was issued a Notice of Amendment on January 21, 2022, which proposed amendment of your procedures. TGC submitted its amended procedures on February 24, 2022. 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#