{"operation":"document","citation":"CPF 12022024NOA","title":"ELIZABETHTOWN NATURAL GAS — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-02-24","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022024noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022024noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022024noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022024NOA","body":"Notice of Amendment involving ELIZABETHTOWN NATURAL GAS. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2022-02-24 and is reported as closed as of 2022-03-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022024NOA_Closure Letter_03252022_(20-173594).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022024NOA/12022024NOA_Closure%20Letter_03252022_(20-173594).pdf\n\n12022024NOA_Closure Letter_03252022_(20-173594)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022024NOA/12022024NOA_Closure%20Letter_03252022_(20-173594)_text.pdf\n\n12022024NOA_Notice of Amendment_02242022_(20-173594).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022024NOA/12022024NOA_Notice%20of%20Amendment_02242022_(20-173594).pdf\n\n12022024NOA_Notice of Amendment_02242022_(20-173594)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022024NOA/12022024NOA_Notice%20of%20Amendment_02242022_(20-173594)_text.pdf\n\n12022024NOA_Operator Response to Notice_03102022_(20-173594).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022024NOA/12022024NOA_Operator%20Response%20to%20Notice_03102022_(20-173594).pdf\n\n12022024NOA_Closure Letter_03252022_(20-173594)_text.pdf\n\nVIA ELECTRONIC MAIL TO: matthew.hobbs@elizabethtownky.gov\nMarch 25, 2022\nMr. Matthew Hobbs\nGas System Engineer\nElizabethtown Natural Gas\n200 W. Dixie\nP.O. Box 550\nElizabethtown, Kentucky 42701\nCPF-1-2022-024-NOA\nDear Mr. Hobbs:\nFrom November 2 to 5, 2020 and April 26, 2021, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Elizabethtown Natural Gas’s (ENG) Cecilia Storage procedures for underground natural\ngas storage in Elizabethtown, Indiana. As a result of the inspection, Elizabethtown was issued a\nNotice of Amendment on February 24, 2022, which proposed amendment of your procedures.\nElizabethtown submitted its amended procedures on March 10, 2022. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\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\n\n12022024NOA_Notice of Amendment_02242022_(20-173594)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nFebruary 24, 2022\nMr. Matthew Hobbs\nGas System Engineer\nElizabethtown Natural Gas\n200 W. Dixie\nP.O. Box 550\nElizabethtown, Kentucky 42701\nCPF 1-2022-024-NOA\nDear Mr. Hobbs:\nFrom November 2 to 5, 2020 and April 26, 2021, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Elizabethtown Natural Gas’s (ENG) Cecilia Storage procedures for underground natural\ngas storage in Elizabethtown, Indiana.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nElizabethtown Natural Gas’s plans or procedures, 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 1-2022-024-NOA\nENG’s written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities under § 192.12(b) were inadequate. Specifically, ENG’s Storage\nOperations and Maintenance Manual, dated 4/1/2021 (O&M Manual), lacked details for the\noperation of underground natural gas storage fields with regard to reporting safety related\nconditions (SRCs) in accordance with the requirements of § 191.23 and § 191.25.\nDuring the inspection, PHMSA reviewed the O&M Manual and determined that ENG did not have\na procedure to report SRCs.\nTherefore, ENG’s written procedures required by § 192.12(c) were inadequate. ENG must revise\nits procedures to address SRC reporting requirements.\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 Elizabethtown Natural Gas maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nEastern Region, Pipeline and Hazardous Materials Safety Administration, 840 Bear Tavern Road,\nSuite 300, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF\n1-2022-024-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should\nbe sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office.\n12022024NOA_Notice of Amendment_02242022_(20-173594)_text Page 2 of 3\n\n\n\nCPF 1-2022-024-NOA\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12022024NOA_Notice of Amendment_02242022_(20-173594)_text Page 3 of 3","truncated":false,"body_characters":7568}