{"operation":"document","citation":"CPF 12022045NOA","title":"AMEREN ILLINOIS COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-04-26","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022045noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022045noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022045noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022045NOA","body":"Notice of Amendment involving AMEREN ILLINOIS COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(2). The case was opened on 2022-04-26 and is reported as closed as of 2022-06-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022045NOA_Closure Letter_06162022_(21-209277).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022045NOA/12022045NOA_Closure%20Letter_06162022_(21-209277).pdf\n\n12022045NOA_Closure Letter_06162022_(21-209277)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022045NOA/12022045NOA_Closure%20Letter_06162022_(21-209277)_text.pdf\n\n12022045NOA_Notice of Amendment_04262022_(21-209277).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022045NOA/12022045NOA_Notice%20of%20Amendment_04262022_(21-209277).pdf\n\n12022045NOA_Notice of Amendment_04262022_(21-209277)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022045NOA/12022045NOA_Notice%20of%20Amendment_04262022_(21-209277)_text.pdf\n\n12022045NOA_Operator Response to Notice_05262022_(21-209277).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022045NOA/12022045NOA_Operator%20Response%20to%20Notice_05262022_(21-209277).pdf\n\n12022045NOA_Closure Letter_06162022_(21-209277)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJune 16, 2022\nMr. Richard J. Mark\nChairman and President\nAmeren Illinois Company\n10 Executive Drive\nCollinsville, Illinois 62234\nCPF 1-2022-045-NOA\nDear Mr. Mark:\nFrom April 19, 2021 through April 23, 2021, the Illinois Department of Natural Resources, Office of\nOil and Gas Resource Management (IDNR), acting as a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected Ameren Illinois Company’s (AIC) Lincoln Underground Natural Gas Storage Facility\n(UNGSF) in Logan County, Illinois. As a result of the inspection, AIC was issued a Notice of\nAmendment on April 26, 2022, which proposed amendment of your procedures.\nAIC submitted its amended procedures on May 26, 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\n\n12022045NOA_Notice of Amendment_04262022_(21-209277)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nApril 26, 2022\nMr. Richard J. Mark\nChairman and President\nAmeren Illinois Company\n10 Executive Drive\nCollinsville, Illinois 62234\nCPF 1-2022-045-NOA\nDear Mr. Mark:\nFrom April 19, 2021 through April 23, 2021, the Illinois Department of Natural Resources, Office of\nOil and Gas Resource Management (IDNR), acting as a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected Ameren Illinois Company’s (AIC) Lincoln Underground Natural Gas Storage Facility\n(UNGSF) in Logan County, Illinois.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within AIC’s\nplans or procedures, as described below:\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.\nAIC’s written procedures were inadequate to assure safe operation of a pipeline facility. Specifically,\nAIC’s procedures required by API RP 1171, Section 11.2.1 - Construction, Operation, and\nMaintenance Procedures (Section 11.2.1) were inadequate for the storing, transporting, lifting and\n\n\n\nCPF 1-2022-045-NOA\ninstalling of piping pursuant to API RP 1171, Section 6.3.6 - Handling (Section 6.3.6).\nSection 11.2.1 requires that “[t]he operator shall develop and follow procedures for the construction,\noperation, and maintenance of natural gas storage wells and reservoirs to establish and maintain\nfunctional integrity.” Section 6.3.6 states in part that the “[c]asing shall be stored, transported, lifted\nand installed as specified by the manufacturer and in accordance with API 5C1.”\nDuring the inspection, AIC was not able to provide procedures or records to verify that casing was\nstored, transported, lifted and installed as specified by the manufacturer and in accordance with API\n5C1 for tubing installed in wells Worthington Horney in 2020 and Roller in 2019. Form 6.3, Tubular\nHandling and Transportation Checklist was developed for future well workovers.\nTherefore, AIC’s procedures were inadequate regarding casings. AIC must revise its procedures to\naddress the deficiency noted above.\n2. § 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.\nAIC’s written procedures were inadequate to assure safe operation of a pipeline facility. Specifically,\nAIC’s procedures required by Section 11.2.1 were inadequate regarding safeguards to the environment,\nsafety, and health of workers and the public pursuant to API RP 1171, Section 6.8.1- Design and\nConstruction Safeguards (Section 6.8.1).\nSection 11.2.1 states in part “[t]he operator shall develop and follow procedures for the construction,\noperation, and maintenance of natural gas storage wells and reservoirs to establish and maintain\nfunctional integrity.” Section 6.8.1 states in part “[s]afeguards to the environment, safety, and health\nof workers and the public shall be incorporated into well design and well work activities.”\nDuring the inspection, AIC was not able to provide procedures or records that identified and enforced\nsafeguards to the environment, safety and health of workers and the public prior to well workover on\nWorthington Horney in 2020 and Roller in 2019. No measures were demonstrated to have been taken\nto detect and mitigate H2S gas which was known to be present within the wells in this field. AIC\nprovided a draft of form, Well Work Environmental Safety Checklist, to incorporate for future records.\nTherefore, AIC’s procedures were inadequate regarding safeguards to the environment, safety and\nhealth of workers and the public. AIC must revise its procedures to address the deficiency noted above.\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 part\nof this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\n12022045NOA_Notice of Amendment_04262022_(21-209277)_text Page 2 of 3\n\n\n\nCPF 1-2022-045-NOA\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you submit\nin response to this enforcement action is subject to being made publicly available. If you believe that\nany portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document with the\nportions you believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised procedures,\nor a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this\nNotice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes\nthe Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further\nnotice to you and to issue an Order Directing Amendment. If your plans or procedures are found\ninadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct\nthe inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you\nsubmit your amended procedures to my office within 30 days of receipt of this Notice. This period\nmay be extended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Ameren Illinois Company maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and Hazardous\nMaterials Safety Administration, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. In\ncorrespondence concerning this matter, please refer to CPF 1-2022-045-NOA and, for each document\nyou submit, please provide a copy in electronic format whenever possible. Smaller files may be emailed\nto robert.burrough@dot.gov. Larger files should be sent on USB flash drive accompanied by the\noriginal 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\n12022045NOA_Notice of Amendment_04262022_(21-209277)_text Page 3 of 3","truncated":false,"body_characters":9979}