{"operation":"document","citation":"CPF 12023002NOA","title":"GILL RANCH STORAGE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-01-12","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023002noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023002noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023002noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12023002NOA","body":"Notice of Amendment involving GILL RANCH STORAGE LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2023-01-12 and is reported as closed as of 2023-03-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12023002NOA_Closure Letter_03302023_(21-207382).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023002NOA/12023002NOA_Closure%20Letter_03302023_(21-207382).pdf\n\n12023002NOA_Closure Letter_03302023_(21-207382)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023002NOA/12023002NOA_Closure%20Letter_03302023_(21-207382)_text.pdf\n\n12023002NOA_Notice of Amendment_01122023_(21-207382).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023002NOA/12023002NOA_Notice%20of%20Amendment_01122023_(21-207382).pdf\n\n12023002NOA_Notice of Amendment_01122023_(21-207382)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023002NOA/12023002NOA_Notice%20of%20Amendment_01122023_(21-207382)_text.pdf\n\n12023002NOA_Operator Response to Notice_02092023_(21-207832).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023002NOA/12023002NOA_Operator%20Response%20to%20Notice_02092023_(21-207832).pdf\n\n12023002NOA_Notice of Amendment_01122023_(21-207382)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJanuary 12, 2023\nMr. Mark Stauss\nPresident\nGill Ranch Storage LLC\n10000 Memorial Drive, Suite 330\nHouston, Texas 77024\nCPF 1-2023-002-NOA\nDear Mr. Stauss:\nFrom June 21, 2021, through June 25, 2021, inspectors from the California Geologic Energy\nManagement Division (CalGEM), acting as an agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Gill\nRanch Storage LLC’s (GRS) procedures for the Gill Ranch Storage LLC underground natural gas\nstorage (UNGS) facility in Madera County, California.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within GRS’s\nplans 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\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\n\n\n\nor beginning an activity not yet implemented.\nGRS written procedures for conducting operations and maintenance activities were inadequate to\nensure safe operation of a pipeline facility. Specifically, GRS’s UNGS Task Procedures Task 0331\n(Valve Procedure), presented as its process for maintenance, repair, or replacement of isolation\nvalves, did not address maintenance, repair, or replacement of isolation valves pursuant to API RP\n1171, Section 9.3.2 Well Integrity Monitoring.\nAPI RP 1171, Section 9.3.2 states, in part, that “The valves shall be maintained, repaired, or\nreplaced in accordance with the operator’s valve maintenance program for isolation valves.”\nDuring the inspection, PHMSA reviewed the Valve Procedure. Based on that review, PHMSA\ndetermined that GRS’s Valve Procedure failed to adequately describe a process on how GRS\nmaintains its valves, remediates inoperable valves, and designates the use of alternate valves. The\nreviewed procedures, UNGS Task Procedures Task 0331, did not describe the process for repairing\nand replacing valves. The reviewed procedures stated that a notification would be made to the\narea manager but did not go on to describe the repair or replacement methodologies.\nTherefore, GRS’s written procedures required by § 192.12(c) were inadequate. GRS must revise\nits to address the deficiency outlined 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\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\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 Gill Ranch Storage LLC maintain documentation of the safety\n\n\n\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration, 840 Bear Tavern Road, Suite 300, West Trenton, NJ\n08628. In correspondence concerning this matter, please refer to CPF 1-2023-002-NOA and, for\neach document you submit, please provide a copy in electronic format whenever possible. Smaller\nfiles may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive\naccompanied 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\n\n12023002NOA_Closure Letter_03302023_(21-207382)_text.pdf\n\nCPF 1-2023-002-NOA\nDear Mr. Stauss:\nFrom June 21, 2021, through June 25, 2021, inspectors from the California Geologic Energy\nManagement Division (CalGEM), acting as an agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Gill\nRanch Storage LLC’s (GRS) procedures for the Gill Ranch Storage LLC underground natural gas\nstorage (UNGS) facility in Madera County, California.\nAs a result of the inspection, GRS was issued a Notice of Amendment (Notice), dated January 12,\n2023. In response to the Notice, GRS submitted revised procedures on Feburary 9, 2023.\nMy staff reviewed the amended procedures, and it appears that the inadequacies outlined in this\nNotice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nP.P.\nOVERNIGHT EXPRESS DELIVERY\nMarch 30, 2023\nMr. Mark Stauss\nPresident\nGill Ranch Storage LLC\n10000 Memorial Drive, Suite 330\nHouston, Texas 77024\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":8087}