{"operation":"document","citation":"CPF 12022007NOA","title":"TRUNKLINE GAS CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-01-21","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022007noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022007noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022007noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022007NOA","body":"Notice of Amendment involving TRUNKLINE GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2022-01-21 and is reported as closed as of 2022-03-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022007NOA_Closure Letter_03152022_(21-200490).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022007NOA/12022007NOA_Closure%20Letter_03152022_(21-200490).pdf\n\n12022007NOA_Closure Letter_03152022_(21-200490)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022007NOA/12022007NOA_Closure%20Letter_03152022_(21-200490)_text.pdf\n\n12022007NOA_Notice of Amendment_01212022_(21-200490).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022007NOA/12022007NOA_Notice%20of%20Amendment_01212022_(21-200490).pdf\n\n12022007NOA_Notice of Amendment_01212022_(21-200490)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022007NOA/12022007NOA_Notice%20of%20Amendment_01212022_(21-200490)_text.pdf\n\n12022007NOA_Operator Response to Notice_02242022_(21-200490).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022007NOA/12022007NOA_Operator%20Response%20to%20Notice_02242022_(21-200490).pdf\n\n12022007NOA_Notice of Amendment_01212022_(21-200490)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJanuary 21, 2022\nMr. Matt Ramsey\nPresident and Chief Executive Officer\nTrunkline Gas Company\n8111 Westchester Drive\nDallas, Texas 75225\nCPF 1-2022-007-NOA\nDear Mr. Ramsey:\nFrom June 15, 2021 through June 17, 2021 and on June 24, 2021, representatives of the Pipeline\nand Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.) inspected Trunkline Gas Company’s (TGC) procedures for its Epps Storage\nField in West Carroll County, Louisiana.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within TGC’s\nprocedures, 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 1-2022-007-NOA\nTGC’s written procedures for conducting operations and maintenance activities were inadequate\nto ensure safe operation of a pipeline facility. Specifically, TGC’s written procedures did not\nspecify that its operations & maintenance manuals would be reviewed and updated at intervals not\nto exceed 15 months.\nDuring the inspection, PHMSA reviewed TGC’s UNGS O&M Reservoir Plan. Although TGC’s\nprocedures required an annual review of the O&M manuals, the procedures did not specify that\nthe review interval would not exceed 15 months, but at least once each calendar year, in accordance\nwith § 192.12(c).\nTherefore, TGC’s written procedures required by § 192.12(c) were inadequate. TGC must revise\nits procedures to address the review frequency of its O&M manuals.\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.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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 Trunkline Gas Company maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration, 840 Bear Tavern Road, Suite 300, West Trenton, NJ\n08628. In correspondence concerning this matter, please refer to CPF 1-2022-007-NOA and, for\neach document you submit, please provide a copy in electronic format whenever possible. Smaller\nfiles may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive\n12022007NOA_Notice of Amendment_01212022_(21-200490)_text Page 2 of 3\n\n\n\nCPF 1-2022-007-NOA\naccompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12022007NOA_Notice of Amendment_01212022_(21-200490)_text Page 3 of 3\n\n12022007NOA_Closure Letter_03152022_(21-200490)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMarch 15, 2022\nMr. Matt Ramsey\nPresident and Chief Executive Officer\nTrunkline Gas Company\n8111 Westchester Drive\nDallas, Texas 75225\nCPF 1-2022-007-NOA\nDear Mr. Ramsey:\nFrom June 15, 2021 through June 17, 2021 and on June 24, 2021, representatives from the Pipeline\nand Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, conducted an underground natural gas storage inspection of Trunkline Gas\nCompany’s (TGC) procedures in West Carroll County, Louisiana. As a result of the inspection,\nTGC was issued a Notice of Amendment on January 21, 2022, which proposed amendment of\nyour procedures.\nTGC submitted its amended procedures on February 24, 2022. 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","truncated":false,"body_characters":7557}