{"operation":"document","citation":"CPF 12022055WL","title":"INDIANA GAS CO INC — 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 191.25(a), 192.12(b)(2), 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022055wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022055wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022055wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022055WL","body":"Warning Letter involving INDIANA GAS CO INC. PHMSA's enforcement data identifies the cited regulations as 191.25(a),  192.12(b)(2),  192.12(c). 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\n12022055WL_Warning Letter_05102022_(21-221076).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022055WL/12022055WL_Warning%20Letter_05102022_(21-221076).pdf\n\n12022055WL_Warning Letter_05102022_(21-221076)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022055WL/12022055WL_Warning%20Letter_05102022_(21-221076)_text.pdf\n\n12022055WL_Warning Letter_05102022_(21-221076)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMay 10, 2022\nMr. Scott Doyle\nPresident and Chief Executive Officer\nIndiana Gas Company Inc.\n211 NW Riverside Drive\nEvansville. Indiana 47708\nCPF 1-2022-055-WL\nDear Mr. Doyle:\nFrom October 18 through 21, 2021, the Indiana Department of Natural Resources (IDNR) acting\nas a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA)\npursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Indiana Gas Company Inc.\n(IGC) Unionville Storage’s Underground Natural Gas Facility in Evansville, Indiana.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violation are:\n1. § 191.25 Filing safety-related condition reports.\n(a) Each report of a safety-related condition under § 191.23(a)(1)\nthrough (9) must be filed (received by the Associate Administrator) in\nwriting within 5 working days (not including Saturday, Sunday, or\nFederal holidays) after the day a representative of an operator first\ndetermines that the condition exists, but not later than 10 working days\nafter the day a representative of an operator discovers the condition.\nSeparate conditions may be described in a single report if they are\nclosely related. Reporting methods and report requirements are\ndescribed in paragraph (c) of this section.\nIGC failed to file a safety related condition (SRC) report within the reporting requirements of\n§ 191.25(a). Specifically, IGC failed to file a report within 5 working days after the day a\n\n\n\nCPF 1-2022-055-WL\nrepresentative first determined that a condition existed, but not later than 10 working days after\nthe day a representative of IGC discovered the condition for a 92% corrosion anomaly meeting §\n191.23(a)(2) on its Well UND 13F.\nSection 191.23(a)(2) states:\n(a) Except as provided in paragraph (b) of this section, each operator shall report in accordance\nwith § 191.25 the existence of any of the following safety-related conditions involving\nfacilities in service:\n(1) …\n(2) In the case of a UNGSF, general corrosion that has reduced the wall thickness of any metal\ncomponent to less than that required for the well's maximum operating pressure, or\nlocalized corrosion pitting to a degree where leakage might result.\nDuring the inspection, IDNR was informed that IGC performed an integrity assessment on Well\nUND 13F on May 5, 2020. This assessment resulted in the discovery of a 92% corrosion anomaly\non Well UND 13F on May 20, 2020. IGC provided a white paper detailing a potential inaccuracy\nwith this result but took no additional action to verify the accuracy of the result. After the\ninspection, additional logs were run in December of 2021 and subsequently an SRC report was\nfiled on January 6, 2022 for this condition.\nTherefore, IGC failed to report safety related condition in accordance with the reporting\nrequirements of § 191.25.\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\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.\nIGC failed to meet the provisions of API RP 1171, Section 9. Specifically, IGC failed to monitor\nits wells for annular pressure or gas flow in accordance with API RP 1171, Section 9.3.2 (Section\n9.3.2).\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, IGC was unable to provide any records that it had monitored the annual\npressure or gas flow from 2018 to the second quarter of 2021 for its wells.\n12022055WL_Warning Letter_05102022_(21-221076)_text Page 2 of 4\n\n\n\nCPF 1-2022-055-WL\nTherefore, IGC failed to meet the provisions of Section 9.3.2 regarding monitoring the annular\npressure or gas flows.\n3. § 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.\nIGC failed to review its manuals of written procedures at intervals not exceeding 15 months, but\nat least once each calendar year. Specifically, IGS failed to review its Blowout Contingency Plan\nduring 2020.\nDuring the inspection, IDNR requested records demonstrating that IGC had reviewed its manuals\nrequired by § 192.12(c). IGC was unable to produce a record demonstrating that the Blowout\nContingency Plan had been reviewed in 2020.\nTherefore, IGC failed to review its manuals of written procedures during calendar year 2020 in\naccordance with § 192.12(c).\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\n12022055WL_Warning Letter_05102022_(21-221076)_text Page 3 of 4\n\n\n\nCPF 1-2022-055-WL\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in\nIndiana Gas Company Inc. 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 1-2022-055-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).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n12022055WL_Warning Letter_05102022_(21-221076)_text Page 4 of 4","truncated":false,"body_characters":9238}