{"operation":"document","citation":"CPF 12022026NOA","title":"DOMINION ENERGY OHIO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-04-07","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022026noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022026noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022026noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022026NOA","body":"Notice of Amendment involving DOMINION ENERGY OHIO. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2022-04-07 and is reported as closed as of 2022-05-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022026NOA_Closure Letter_05262022_(20-177104).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022026NOA/12022026NOA_Closure%20Letter_05262022_(20-177104).pdf\n\n12022026NOA_Closure Letter_05262022_(20-177104)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022026NOA/12022026NOA_Closure%20Letter_05262022_(20-177104)_text.pdf\n\n12022026NOA_Notice of Amendment_04072022_(20-177104).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022026NOA/12022026NOA_Notice%20of%20Amendment_04072022_(20-177104).pdf\n\n12022026NOA_Notice of Amendment_04072022_(20-177104)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022026NOA/12022026NOA_Notice%20of%20Amendment_04072022_(20-177104)_text.pdf\n\n12022026NOA_Operator Response to Notice_04262022_(20-177104).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022026NOA/12022026NOA_Operator%20Response%20to%20Notice_04262022_(20-177104).pdf\n\n12022026NOA_Notice of Amendment_04072022_(20-177104)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nApril 7, 2022\nMr. P. Rodney Blevins\nPresident, Gas Distribution\nDominion Energy Ohio\n120 Tredegar Street\nRichmond, Virginia 23219\nCPF 1-2022-026-NOA\nDear Mr. Blevins:\nFrom June 23, 2020 to June 25, 2020, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nDominion Energy Ohio’s (DEO) procedures for construction in North Canton, Ohio.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within DEO’s\nplans 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.\nDEO’s written procedures for conducting activities were inadequate to ensure safe operation of a\n\n\n\nCPF 1-2022-026-NOA\npipeline facility in accordance with § 192.12(c). Specifically, DEO’s Storage Integrity\nManagement Program (Well and Reservoir), Well Integrity Standard, updated 7/10/2020 (SIMP),\nfailed to provide sufficient details for performing production casing pressure tests pursuant to API\nRP 1171, Section 6.9.1 (Section 6.9.1).1\nDuring the inspection, PHMSA reviewed DEO’s SIMP, subsection S30.7. That subsection\nrepeated the exact language of Section 6.9.1, including the details of commonly used test\nparameters for pressure and duration as shown in the example provided in Section 6.9.1. However,\nthe SIMP did not include additional details for performing production casing pressure tests, such\nas the appropriate test pressure and duration so that the maximum pressure on the packer seat and\nthe pressure at any point in the wellbore during the test does not compromise the mechanical\nintegrity of the well.\nTherefore, DEO’s written procedures for conducting activities were inadequate to ensure safe\noperation of a pipeline facility in accordance with § 192.12(c). DEO must revise its SIMP to\ninclude the required details for performing production casing pressure tests, such as the appropriate\ntest pressure and duration, as required by Section 6.9.1.\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\nthe document with the portions you believe qualify for confidential treatment redacted and an\n1 API RP 1171, 6.9.1 Testing Methods\nA new well, or a well that has had its existing production casing modified from its previous condition during workover\nactivities, shall be tested to demonstrate mechanical integrity and suitability for the designed operating conditions\nprior to commissioning by one of the following tests.\na) For new well construction, the production casing shall be tested prior to drilling out the shoe, taking into account\nthe cement design factors so that this test does not compromise the cement integrity.\nb) For existing production casing, the production casing shall be tested after setting a retrievable plug as close as\npractical to the top of the storage formation.\nNOTE A commonly used test parameter is an initial test pressure of 1.1 times the maximum allowable operating\npressure, with test duration of at least 30 minutes and a pressure drop not exceeding 10% of the initial test pressure.\nApplicable regulations may stipulate other parameters.\nc) For a well completed with tubing and packer, the tubing-casing annulus shall be tested.\nThe operator shall design a test so the maximum pressure on the packer seat and the pressure at any point in the\nwellbore during the test does not compromise the mechanical integrity of the well.\n12022026NOA_Notice of Amendment_04072022_(20-177104)_text Page 2 of 3\n\n\n\nCPF 1-2022-026-NOA\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 Dominion Energy Ohio 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 1-2022-026-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\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\n12022026NOA_Notice of Amendment_04072022_(20-177104)_text Page 3 of 3\n\n12022026NOA_Closure Letter_05262022_(20-177104)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMay 26, 2022\nMr. P. Rodney Blevins\nPresident, Gas Distribution\nDominion Energy Ohio\n120 Tredegar Street\nRichmond, Virginia 23219\nCPF 1-2022-026-NOA\nDear Mr. Blevins:\nFrom June 23, 2020 to June 25, 2020, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an\non-site pipeline safety inspection of Dominion Energy Ohio’s (DEO) procedures for construction\nin North Canton, Ohio. As a result of the inspection, DEO was issued a Notice of Amendment on\nApril 7, 2022, which proposed amendment of your procedures.\nDEO submitted its amended procedures on May 6, 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":9329}