{"operation":"document","citation":"CPF 12022009WL","title":"TEXAS GAS TRANSMISSION, LLC — 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-12022009wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022009wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022009wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022009WL","body":"Warning Letter involving TEXAS GAS TRANSMISSION, LLC. 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\n12022009WL_Warning Letter_02082022_(21-173256).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022009WL/12022009WL_Warning%20Letter_02082022_(21-173256).pdf\n\n12022009WL_Warning Letter_02082022_(21-173256)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022009WL/12022009WL_Warning%20Letter_02082022_(21-173256)_text.pdf\n\n12022009WL_Warning Letter_02082022_(21-173256)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nFebruary 8, 2022\nMr. Jeff Sanderson\nVice President Field Operations Safety and Security\nTexas Gas Transmission, LLC\n9 Greenway Plaza, Suite 2800\nHouston, Texas 77046\nCPF 1-2022-009-WL\nDear Mr. Sanderson:\nFrom June 1 to June 5, 2020 and April 29, 2021, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected Texas Gas Transmission, LLC’s (Texas) Oaktown Underground Natural Gas Storage in\nOaktown, Indiana.\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.\nTexas failed to meet the provisions of API RP 1171 section 9. Specifically, Texas failed to inspect the\nmaster gate valves in accordance with API RP 1171, Section 9.3.2 (Section 9.3.2).\nSection 9.3.2 states in part:\n\n\n\nCPF 1-2022-009-WL\nThe operator shall visually inspect each wellhead assembly at least annually for leaks. The\noperator shall test the operation of the master valve and wellhead pipeline isolation valve at\nleast annually for proper function and ability to isolate the well. The valves shall be\nmaintained, repaired, or replaced in accordance with the operator’s valve maintenance\nprogram for isolation valves.\nDuring the inspection, Texas was not able to provide records of the inspection of all master gate valves.\nPHMSA noted that certain wells did not have master gate valves or had siphon strings inserted through\nthe existing master gate valve. Texas confirmed they had not inspected the master gate valves which\nhad siphon strings inserted.\nTherefore, Texas failed to meet the provisions of Section 9.3.2.\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 Texas Gas Transmission,\nLLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF\n1-2022-009-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\n12022009WL_Warning Letter_02082022_(21-173256)_text Page 2 of 2","truncated":false,"body_characters":5329}