{"operation":"document","citation":"CPF 12022054NOA","title":"MOUNTAINWEST PIPELINE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-06-02","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022054noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022054noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022054noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022054NOA","body":"Notice of Amendment involving MOUNTAINWEST PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2022-06-02 and is reported as closed as of 2022-07-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022054NOA_Closure Letter_07122022_(21-200067).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022054NOA/12022054NOA_Closure%20Letter_07122022_(21-200067).pdf\n\n12022054NOA_Closure Letter_07122022_(21-200067)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022054NOA/12022054NOA_Closure%20Letter_07122022_(21-200067)_text.pdf\n\n12022054NOA_Notice of Amendment_06022022_(21-200067).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022054NOA/12022054NOA_Notice%20of%20Amendment_06022022_(21-200067).pdf\n\n12022054NOA_Notice of Amendment_06022022_(21-200067)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022054NOA/12022054NOA_Notice%20of%20Amendment_06022022_(21-200067)_text.pdf\n\n12022054NOA_Operator Response to Notice_06222022_(21-200067).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022054NOA/12022054NOA_Operator%20Response%20to%20Notice_06222022_(21-200067).pdf\n\n12022054NOA_Notice of Amendment_06022022_(21-200067)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJune 2, 2022\nMs. Colleen Larkin Bell\nPresident and Chief Executive Officer\nMountainWest Pipeline, LLC\nP. O. Box 453360\nSalt Lake City, Utah 84145\nCPF 1-2022-054-NOA\nDear Ms. Larkin Bell:\nFrom June 2, 2021 through June 4, 2021, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the\nunderground natural gas facility procedures of MountainWest Pipeline, LLC’s1 (MWP) Leroy\nStorage in Salt Lake City, Utah.\nOn the basis of the inspection, PHMSA has identified an apparent inadequacy found within\nMWP’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\n1 At the time of the inspection, the operator of the Leroy Storage was known as Dominion Energy Questar Pipeline,\nLLC. Dominion Energy Questar Pipeline, LLC and associated assets were acquired by South West Gas Holding\nCompany on January 1, 2022. As part of the acquisition the company name was changed on April 1, 2022 to\nMountainWest Pipeline, LLC.\n\n\n\nCPF 1-2022-054-NOA\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.\nMWP’s written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities were inadequate to ensure safe operation of a pipeline facility. Specifically,\nMWP failed to include in its manuals a procedure for determining that the ground water and\nhydrocarbon zones were sealed off prior to plugging and abandoning a well pursuant to API RP\n1171, Section 6.7.2 (Section 6.7.2), as required by API RP 1171, Section 11.2.1 (Section 11.2.1).\nSection 11.2.1 states in relevant part that “[t]he operator shall develop and follow procedures for\nthe construction, operation, and maintenance of natural gas storage wells and reservoirs to establish\nand maintain functional integrity.” Section 6.7.2 states in relevant part:\nThe operator shall use cement plugs (see 6.4.3) and/or mechanical plugs to isolate\nthe storage zone from fluid migration. The use of hydrostatic pressure as a sole\nmeans of isolation shall not be acceptable… The operator shall determine the\nlocation of groundwater and hydrocarbon bearing zones (in addition to the storage\nzone) penetrated by the well to be abandoned, and the condition of the well's casing\nand cement across those zones, to prevent communication between any of those\nzones during and after plugging of the well. Special provisions may be necessary\nto isolate formations behind uncemented casing.\nDuring the inspection, PHMSA reviewed procedures and records relative to the plugging and\nabandoning of MWP’s well Leroy #5. MWP was not able to provide current or prior procedures\naddressing verification that the ground water and hydrocarbon zones were identified prior to\nplugging and abandoning or sealed off so that migration of fluids would not occur.\nTherefore, MWP’s written procedures were inadequate. MWP must revise its procedures to\naddress Section 6.7.2 requirements when plugging and abandoning a well.\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\n12022054NOA_Notice of Amendment_06022022_(21-200067)_text Page 2 of 3\n\n\n\nCPF 1-2022-054-NOA\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 MountainWest Pipeline, LLC 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\n1-2022-054-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.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12022054NOA_Notice of Amendment_06022022_(21-200067)_text Page 3 of 3\n\n12022054NOA_Closure Letter_07122022_(21-200067)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJuly 12, 2022\nMs. Colleen Larkin Bell\nPresident and Chief Executive Officer\nMountainWest Pipeline, LLC\nP. O. Box 453360\nSalt Lake City, Utah 84145\nCPF 1-2022-054-NOA\nDear Ms. Larkin Bell:\nFrom June 2, 2021 through June 4, 2021, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the\nunderground natural gas facility procedures of MountainWest Pipeline, LLC’s (MWP) Leroy\nStorage in Salt Lake City, Utah. As a result of the inspection, MWP was issued a Notice of\nAmendment on June 2, 2022, which proposed amendment of your procedures.\nMWP submitted its amended procedures on June 22, 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":9043}