{"operation":"document","citation":"CPF 12022068NOA","title":"PUBLIC SERVICE CO OF COLORADO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-08-18","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(b)(2), 192.12(d)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022068noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022068noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022068noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022068NOA","body":"Notice of Amendment involving PUBLIC SERVICE CO OF COLORADO. PHMSA's enforcement data identifies the cited regulations as 192.12(b)(2),  192.12(d)(4). The case was opened on 2022-08-18 and is reported as closed as of 2022-09-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022068NOA_Closure Letter_09292022_(21-200486).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022068NOA/12022068NOA_Closure%20Letter_09292022_(21-200486).pdf\n\n12022068NOA_Closure Letter_09292022_(21-200486)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022068NOA/12022068NOA_Closure%20Letter_09292022_(21-200486)_text.pdf\n\n12022068NOA_Notice of Amendment_08182022_(21-200486).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022068NOA/12022068NOA_Notice%20of%20Amendment_08182022_(21-200486).pdf\n\n12022068NOA_Notice of Amendment_08182022_(21-200486)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022068NOA/12022068NOA_Notice%20of%20Amendment_08182022_(21-200486)_text.pdf\n\n12022068NOA_Operator Response to Notice_09162022_(21-200486).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022068NOA/12022068NOA_Operator%20Response%20to%20Notice_09162022_(21-200486).pdf\n\n12022068NOA_Notice of Amendment_08182022_(21-200486)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nAugust 18, 2022\nMr. Luke Litteken\nSenior Vice President, Gas\nPublic Service Co of Colorado\n1123 W. 3rd Avenue\nDenver, Colorado 80223\nCPF 1-2022-068-NOA\nDear Mr. Litteken:\nFrom May 3, 2021 through May 7, 2021, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nPublic Service Co of Colorado’s (PSCC) procedures for Roundup Underground Natural Gas\nStorage Facility (Roundup) in Morgan County, Colorado.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nPSCC’s plans 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\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.\nPSCC’s written procedures were inadequate to assure safe operation of a pipeline facility.\nSpecifically, PSCC’s procedures required by API RP 1171, Section 11.2.1 failed to address API\n\n\n\nRP 1171, Sections 6.3.5, 6.3.6, 6.3.7, 6.7.1, 6.9.1, 6.10.4 and 6.11.2. 1\nSection 11.2.1 states in part that “[t]he operator shall develop and follow procedures for the\nconstruction, operation, and maintenance of natural gas storage wells and reservoirs to establish\nand maintain functional integrity.”\nDuring the inspection, PSCC was not able to provide procedures addressing how it complies and\nmaintain records relative to the aforementioned Section 6 requirements of API RP 1171. Thus,\nPSCC was unable to demonstrate that procedures were in place by January 18, 2018, or prior to\nthe construction/workovers of wells #1, 10, and 20 or the plugging and abandoning of wells #2\nand 33.\nTherefore, PSCC’s procedures were inadequate regarding portions of Section 6 of API RP 1171.\nPSCC must develop and follow procedures relative to these portions of Section 6 as required by\nSection 11.2.1.\n2. § 192.12 Underground natural gas storage facilities.\n(a) …\n(d) Integrity management program--\n(1) …\n(4) Integrity management procedures and recordkeeping. Each\nUNGSF operator must establish and follow written procedures to carry\nout its integrity management program under API RP 1171\n(incorporated by reference, see § 192.7), section 8 (\"Risk Management\nfor Gas Storage Operations\"), and this paragraph (d). The operator\nmust also maintain, for the useful life of the UNGSF, records that\ndemonstrate compliance with the requirements of this paragraph (d).\nThis includes records developed and used in support of any\nidentification, calculation, amendment, modification, justification,\ndeviation, and determination made, and any action taken to implement\nand evaluate any integrity management program element.\nPSCC’s procedures for carrying out its integrity management program were inadequate to ensure\nsafe operation of a pipeline facility. Specifically, PSCC’s Underground Storage Risk and Integrity\nManagement Plan (IMP) did not provide specific information to be used to determine threat\ninteraction susceptibility to threat and hazard-related events in accordance with API RP 1171,\nSection 8.3.2 (Section 8.3.2).\nSection 8.3.2 states:\nThe operator shall use available information such as performance data collected through the\nfield history, operations and maintenance (O&M) activities, geotechnical data such as well\nlogs, engineering data, and completion reports to determine susceptibility to threat and\nhazard-related events and to assess threat and hazard interaction.\nDuring the inspection. PSCC’s IMP was reviewed, and it did not list available data used to\ndetermine threat interaction susceptibility to threat and hazard-related events.\n\n\n\nTherefore, PSCC’s written procedures required by § 192.12(d)(4) were inadequate. PSCC must\nrevise its procedures to include using all available data to determine threat interaction susceptibility\nto threat and hazard-related events in accordance with API 1171, Section 8.3.2.\n3. § 192.12 Underground natural gas storage facilities.\n(a) …\n(d) Integrity management program--\n(1) …\n(4) Integrity management procedures and recordkeeping. Each\nUNGSF operator must establish and follow written procedures to carry\nout its integrity management program under API RP 1171\n(incorporated by reference, see § 192.7), section 8 (\"Risk Management\nfor Gas Storage Operations\"), and this paragraph (d). The operator\nmust also maintain, for the useful life of the UNGSF, records that\ndemonstrate compliance with the requirements of this paragraph (d).\nThis includes records developed and used in support of any\nidentification, calculation, amendment, modification, justification,\ndeviation, and determination made, and any action taken to implement\nand evaluate any integrity management program element.\nPSCC’s procedures for carrying out its integrity management program were inadequate to ensure\nsafe operation of a pipeline facility. Specifically, PSCC’s IMP failed to include requirements for\ndeveloping and documenting preventative and mitigative measures (P&M Measures) in\naccordance with API RP 1171, Section 8.6.2 (Section 8.6.2).\nSection 8.6.2 states:\nThe operator shall develop P&M measures to manage risks.\nThe operator should review the P&M measures listed in Table 2 to determine those\nmeasures that manage risks based on site-specific conditions. Not all risks need a P&M\nmeasure if the level of risk is fully acceptable or if it is not necessary to reduce risk by\nfurther efforts.\nThe operator should employ the effective P&M measures and train their personnel on the\nprocedures related to the P&M measures (see Section 11). The operator can apply these\nP&M measures to individual wells, individual reservoirs or fields, and/or groups of wells or\nfields.\nDuring the inspection, PHMSA reviewed PSCC’s IMP and found that it did not contain a process\nfor developing and documenting P&M Measures.\nPSCC’s written procedures required by § 192.12(d)(4) were inadequate. PSCC must revise its\nprocedures to include detailed information about P&M Measures in accordance with API 1171,\nSection 8.6.2.\n4. § 192.12 Underground natural gas storage facilities.\n\n\n\n(a) …\n(d) Integrity management program--\n(1) …\n(4) Integrity management procedures and recordkeeping. Each\nUNGSF operator must establish and follow written procedures to carry\nout its integrity management program under API RP 1171\n(incorporated by reference, see § 192.7), section 8 (\"Risk Management\nfor Gas Storage Operations\"), and this paragraph (d). The operator\nmust also maintain, for the useful life of the UNGSF, records that\ndemonstrate compliance with the requirements of this paragraph (d).\nThis includes records developed and used in support of any\nidentification, calculation, amendment, modification, justification,\ndeviation, and determination made, and any action taken to implement\nand evaluate any integrity management program element.\nPSCC’s written procedures for carrying out its integrity management program were inadequate to\nensure safe operation of a pipeline facility. Specifically, PSCC’s IMP failed to include a specified\ninterval for a continual review and improvement cycle for its risk management activities in\naccordance with API RP 1171, Section 8.7.1.\nSection 8.7.1 states:\nThe operator shall assess the effectiveness of risk monitoring and risk management\nprograms and maintain a continual review and improvement cycle in risk management\nactivities to provide functional integrity of the storage operation. The interval of review and\nreassessment should be short enough to identify operational and monitoring trends and\nmeasure the effectiveness of P&M measures, but long enough that the data and information\nthat can be brought into the analysis are meaningful.\nDuring the inspection, PSCC’s IMP was reviewed, and it did not include a required interval for\nreview and reassessment of its risk management activities.\nTherefore, PSCC’s written procedures required by § 192.12(d)(4) were inadequate. PSCC must\nrevise its procedures to include a frequency requirement pursuant to the assessment required by\nAPI 1171, Section 8.7.1.\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\n\n\n\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\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 Public Service Co of Colorado 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\n1-2022-068-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\n1 Section 6.3.5 states in part:\nThe production casing, which provides access to the storage interval, shall be of adequate size and strength\nto maintain the well integrity and be compatible with fluid chemical composition.\nSection 6.3.6 states in part:\nCasing shall be stored, transported, lifted and installed as specified by the manufacturer and in accordance\nwith API 5C1.\nSection 6.3.7 states in part:\nCasing connections shall be designed to accommodate loads associated with placement. The operator\nshould calculate the expected mechanical load conditions for casing in the vertical and/or directionally\noriented conditions during running, cementing, drilling, and operations and design the casing to have\nmechanical properties in excess of the mechanical load conditions. The casing shall maintain a gas seal\n\n\n\nunder anticipated wellbore flow conditions and subsequent work in the wellbore (drilling, stimulation, and\nremediation).\nCasing connections shall be made up according to manufacturer specifications or in accordance with API\n5CT.\nThread compound or lubricant shall be compatible with the expected wellbore environment and shall be\nconsistent with the manufacturer’s recommended lubricant or API 5A3.\nSection 6.7.1 states in part:\nThe operator shall design a well abandonment for long-term isolation of the storage zone in order to\nprevent fluid flow between the storage zone and any other penetrated zone and the surface.\nSection 6.9.1 states in part:\nA new well, or a well that has had its existing production casing modified from its previous condition\nduring workover activities, shall be tested to demonstrate mechanical integrity and suitability for the\ndesigned operating conditions prior to commissioning by one of the following tests.\na) For new well construction, the production casing shall be tested prior to drilling out the shoe,\ntaking into account the cement design factors so that this test does not compromise the cement\nintegrity.\nb) For existing production casing, the production casing shall be tested after setting a retrievable\nplug as close as practical to the top of the storage formation.\nSection 6.10.4 states in part:\nThe operator shall resolve issues or problems in a manner that maintains functional integrity of the well and\nstorage reservoir prior to commissioning the well for service.\nSection 6.11.2 states in part:\nRecords relating to permitting, procedures, personnel, and equipment shall be retained for a period that\nmeets regulatory requirements, or where no regulatory requirements exist, intervals as determined by the\noperator. These records shall include, as applicable and available, the items listed below as referenced in\neach subsection.\n— 6.8 Environmental, Health, and Safety\n— On-site safety meeting records.\n— 6.10 Monitoring of Construction Activities\n— Supervisor qualifications.\n— Contractor personnel qualifications.\n— Equipment suitability records.\n— Contractor safety orientation.\n\n12022068NOA_Closure Letter_09292022_(21-200486)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nSeptember 29, 2022\nMr. Luke Litteken\nSenior Vice President, Gas\nPublic Service Co of Colorado\n1123 W. 3rd Avenue\nDenver, Colorado 80223\nCPF 1-2022-068-NOA\nDear Mr. Litteken:\nFrom May 3 through May 7, 2021, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted a\npipeline safety inspection of Public Service Co. of Colorado’s (PSCC) procedures for Roundup\nUnderground Natural Gas Storage Facility in Morgan County, Colorado. As a result of the\ninspection, PSCC was issued a Notice of Amendment on August 18, 2022, which proposed\namendment of your procedures.\nPSCC submitted its amended procedures on September 16, 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":16638}