ELIZABETHTOWN NATURAL GAS — Notice of Amendment

party submissionOfficial PDF12022024NOA_Operator Response to Notice_03102022_(20-173594).pdf#

12022024NOA_Closure Letter_03252022_(20-173594)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: matthew.hobbs@elizabethtownky.gov March 25, 2022 Mr. Matthew Hobbs Gas System Engineer Elizabethtown Natural Gas 200 W. Dixie P.O. Box 550 Elizabethtown, Kentucky 42701 CPF-1-2022-024-NOA Dear Mr. Hobbs: From November 2 to 5, 2020 and April 26, 2021, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Elizabethtown Natural Gas’s (ENG) Cecilia Storage procedures for underground natural gas storage in Elizabethtown, Indiana. As a result of the inspection, Elizabethtown was issued a Notice of Amendment on February 24, 2022, which proposed amendment of your procedures. Elizabethtown submitted its amended procedures on March 10, 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#

12022024NOA_Notice of Amendment_02242022_(20-173594)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY February 24, 2022 Mr. Matthew Hobbs Gas System Engineer Elizabethtown Natural Gas 200 W. Dixie P.O. Box 550 Elizabethtown, Kentucky 42701 CPF 1-2022-024-NOA Dear Mr. Hobbs: From November 2 to 5, 2020 and April 26, 2021, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Elizabethtown Natural Gas’s (ENG) Cecilia Storage procedures for underground natural gas storage in Elizabethtown, Indiana. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within Elizabethtown Natural Gas’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. 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.#

12022024NOA_Notice of Amendment_02242022_(20-173594)_text.pdf, page 2CPF 1-2022-024-NOA ENG’s written procedures for conducting operations, maintenance, and emergency preparedness and response activities under § 192.12(b) were inadequate. Specifically, ENG’s Storage Operations and Maintenance Manual, dated 4/1/2021 (O&M Manual), lacked details for the operation of underground natural gas storage fields with regard to reporting safety related conditions (SRCs) in accordance with the requirements of § 191.23 and § 191.25. During the inspection, PHMSA reviewed the O&M Manual and determined that ENG did not have a procedure to report SRCs. Therefore, ENG’s written procedures required by § 192.12(c) were inadequate. ENG must revise its procedures to address SRC reporting requirements. 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 Elizabethtown Natural Gas 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 1-2022-024-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. 12022024NOA_Notice of Amendment_02242022_(20-173594)_text Page 2 of 3#

12022024NOA_Notice of Amendment_02242022_(20-173594)_text.pdf, page 3CPF 1-2022-024-NOA Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings 12022024NOA_Notice of Amendment_02242022_(20-173594)_text Page 3 of 3#