# ANR PIPELINE CO — Warning Letter

- **operation:** document
- **citation:** CPF 12022032WL
- **title:** ANR PIPELINE CO — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2022-03-15
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 191.17(c).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-12022032wl.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-12022032wl.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-12022032wl
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12022032WL
**body:**

Warning Letter involving ANR PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 191.17(c). The case was opened on 2022-03-15 and is reported as closed as of 2022-03-15. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12022032WL_Warning Letter_03152022_(21-200756).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022032WL/12022032WL_Warning%20Letter_03152022_(21-200756).pdf

12022032WL_Warning Letter_03152022_(21-200756)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022032WL/12022032WL_Warning%20Letter_03152022_(21-200756)_text.pdf

12022032WL_Warning Letter_03152022_(21-200756)_text.pdf

WARNING LETTER
OVERNIGHT EXPRESS DELIVERY
March 15, 2022
Mr. Stanley Chapman III
EVP & President US & MX Natural Gas PL
ANR Pipeline Co
7000 Louisiana Street
Houston, Texas 77002
CPF 1-2022-032-WL
Dear Mr. Chapman:
From July 27 to July 29, 2021, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected
ANR Pipeline Co’s (ANR) Lincoln-Freeman Underground Natural Gas Storage Facility in Lake,
Michigan.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and
the probable violation is:
1. § 191.17 Transmission systems; gathering systems; liquefied natural gas facilities;
and underground natural gas storage facilities: Annual report
(a) …
(c) Underground natural gas storage facility. Each operator of a
UNGSF must submit an annual report through DOT Form PHMSA
7100.4-1. This report must be submitted each year, no later than March
15, for the preceding calendar year.
ANR failed to submit accurate underground natural gas storage facility annual reports to PHMSA
from 2017 to 2021 by failing to include two wells in the total well count for Lincoln-Freeman.
During the inspection of Lincoln-Freeman, it was found that ANR had two wells that were unique



CPF 1-2022-032-WL
to the storage facility. Upon discussion, the wells were identified as observations wells that were
installed due to a previous incident. The wells do not see formation pressure but were installed to
observe the storage horizon. These wells were not included into the annual reports submitted to
PHMSA from 2017 to 2021.
Therefore, ANR failed to meet the requirements of § 191.17(c).
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related
series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021,
the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to
a maximum of $2,225,034 for a related series of violations. For violation occurring on or after
July 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per
violation per day the violation persists, up to a maximum of $2,186,465 for a related series of
violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the
maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to
exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November
27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum
penalty not to exceed $2,090,022.
We have reviewed the circumstances and supporting documents involved in this case and have
decided not to conduct additional enforcement action or penalty assessment proceedings at this
time. We advise you to correct the item(s) identified in this letter. Failure to do so will result in
ANR Pipeline Co being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 1-2022-032-WL. 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).
Sincerely,
Robert Burrough
Director, Eastern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
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