{"operation":"document","citation":"CPF 12022053WL","title":"MOUNTAINWEST PIPELINE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-05-10","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022053wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022053wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022053wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022053WL","body":"Warning Letter involving MOUNTAINWEST PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(2). The case was opened on 2022-05-10 and is reported as closed as of 2022-05-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022053WL_Warning Letter_05102022_(21-200067).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022053WL/12022053WL_Warning%20Letter_05102022_(21-200067).pdf\n\n12022053WL_Warning Letter_05102022_(21-200067)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022053WL/12022053WL_Warning%20Letter_05102022_(21-200067)_text.pdf\n\n12022053WL_Warning Letter_05102022_(21-200067)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMay 10, 2022\nMs. Colleen Larkin Bell\nPresident and Chief Executive Officer\nMountainwest Pipeline, LLC\n333 South State Street\nP. O. Box 453360\nSalt Lake City, Utah 84145\nCPF 1-2022-053-WL\nDear Ms. Larkin Bell:\nFrom June 2 through 4, 2021, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Dominion\nEnergy Questar Pipeline, LLC (Dominion Questar) Leroy Storage’s procedures for Underground\nNatural Gas Facilities in Salt Lake City, Utah.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\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\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see §192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nDominion Questar failed to meet the provisions of API RP 1171, Section 9. Specifically, Dominion\n\n\n\nCPF 1-2022-053-WL\nQuestar failed to demonstrate that it had determined its defined threshold levels based on well\nintegrity evaluation and from risk assessment in accordance with API RP 1171, Section 9.3.2\n(Section 9.3.2).\nSection 9.3.2 states in part, “The operator shall monitor for presence of annular gas by measuring\nand recording annular pressure and/or annular gas flow. The operator shall evaluate each annular\ngas occurrence that exceeds operator- or regulatory-defined threshold levels determined from well\nintegrity evaluation and from risk assessment. The operator should test wellhead seals when\nannulus pressure is detected and where injectable packing and/or test ports are present.”\nDuring the inspection, Dominion Questar identified that its threshold level for annular gas\noccurrences was 1400 psig. Upon PHMSA’s request, Dominion Questar was not able to provide\nan adequate analysis of why their threshold pressure was this high.\nTherefore, Dominion Questar failed to meet the provisions of Section 9.3.2 regarding\ndetermination of its defined thresholds for annular gas occurrences.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for a related\nseries of violations. For violation occurring on or after May 3, 2021 and before March 21, 2022,\nthe maximum penalty may not exceed $225,134 per violation per day the violation persists, up to\na maximum of $2,251,334 for a related series of violations. For violation occurring on or after\nJanuary 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per\nviolation per day the violation persists, up to a maximum of $2,225,034 for a related series of\nviolations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the\nmaximum penalty may not exceed $218,647 per violation per day the violation persists, up to a\nmaximum of $2,186,465 for a related series of violations. For violation occurring on or after\nNovember 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per\nviolation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on\nor after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed\n$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in\nDominion Energy Questar Pipeline, LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2022-053-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\n12022053WL_Warning Letter_05102022_(21-200067)_text Page 2 of 3\n\n\n\nCPF 1-2022-053-WL\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n12022053WL_Warning Letter_05102022_(21-200067)_text Page 3 of 3","truncated":false,"body_characters":5851}