{"operation":"document","citation":"CPF 12023003NOA","title":"PEOPLES GAS LIGHT & COKE CO — 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-12023003noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023003noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023003noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12023003NOA","body":"Notice of Amendment involving PEOPLES GAS LIGHT & COKE CO. 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 2023-06-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12023003NOA_Closure Letter_06012023_(21-220263).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023003NOA/12023003NOA_Closure%20Letter_06012023_(21-220263).pdf\n\n12023003NOA_Closure Letter_06012023_(21-220263)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023003NOA/12023003NOA_Closure%20Letter_06012023_(21-220263)_text.pdf\n\n12023003NOA_Notice of Amendment_01122023_(21-220263).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023003NOA/12023003NOA_Notice%20of%20Amendment_01122023_(21-220263).pdf\n\n12023003NOA_Notice of Amendment_01122023_(21-220263)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023003NOA/12023003NOA_Notice%20of%20Amendment_01122023_(21-220263)_text.pdf\n\n12023003NOA_Operator Response to Notice_02092023_(21-220263).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023003NOA/12023003NOA_Operator%20Response%20to%20Notice_02092023_(21-220263).pdf\n\n12023003NOA_Notice of Amendment_01122023_(21-220263)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJanuary 12, 2023\nMr. Torrence Hinton\nPresident\nPeoples Gas Light and Coke Co\n200 E Randolph Street\nChicago, Illinois 60601\nCPF 1-2023-003-NOA\nDear Mr. Hinton:\nFrom September 27, 2021 through September 30, 2021, the Illinois Department of Natural\nResources, Office of Oil and Gas Resource Management (IDNR), acting as a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.) inspected Peoples Gas Light and Coke Co’s (PGL) procedures for the\nManlove Underground Gas Storage Facility located in Champaign County, Illinois.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nPGL’s plans or procedures, as described below1:\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\n1 All citations are to Title 49 of the Code of Federal Regulations.\n\n\n\nmust have written procedures in place before commencing\noperations or beginning an activity not yet implemented.\nPGL’s written procedures for underground storage were inadequate to assure safe operation of a\npipeline facility. Specifically, PGL’s procedures, required by API RP 1171 (incorporated by\nreference, see § 192.7), Section 11.2.1 failed to address API RP 1171, Sections 6.3.6 and 6.3.72\n.\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, PGL was unable to provide procedures addressing how it follows and\nmaintains records relative to the requirements of these sections of API RP 1171. PGL was unable\nto demonstrate that it had adopted procedures meeting the provisions of API 1171 by January 18,\n2018, and prior to the construction/workovers of well numbers 1, 10, and 20, or the plugging and\nabandoning of well numbers 2 and 33.\nTherefore, PGL’s procedures were inadequate regarding portions of Section 6 of API RP 1171.\nPCL 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(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.\n2 Section 6.3.6 states, in part:\nCasing shall be stored, transported, lifted and installed as specified by the manufacturer and in accordance with API\n5C1.\nSection 6.3.7 states, in part:\nCasing connections shall be designed to accommodate loads associated with placement. The operator should\ncalculate the expected mechanical load conditions for casing in the vertical and/or directionally oriented conditions\nduring running, cementing, drilling, and operations and design the casing to have mechanical properties in excess of\nthe mechanical load conditions. The casing shall maintain a gas seal under anticipated wellbore flow conditions and\nsubsequent work in the wellbore (drilling, stimulation, and remediation).\nCasing connections shall be made up according to manufacturer specifications or in accordance with API 5CT.\nThread compound or lubricant shall be compatible with the expected wellbore environment and shall be consistent\nwith the manufacturer’s recommended lubricant or API 5A3.\n\n\n\nPGL’s written procedures for underground storage were inadequate to assure safe operation of a\npipeline facility. Specifically, PGL’s Underground Storage Risk and Integrity Management Plan\n(IMP) did not include an adequate emergency preparedness/emergency response plan in\naccordance with API RP 1171, Section 10.6.1 (Section 10.6.1).\nSection 10.6.1 Emergency Preparedness/Emergency Response Plan states:\nFor site security and safety, the operator shall develop and implement a structured\nemergency preparedness/response plan in order to address accidental releases, equipment\nfailures, natural disasters, and third-party emergencies. The operator should integrate\nnatural gas storage emergency procedures with regulatory required procedures covering\npipeline facilities where possible rather than creating storage-specific documents.\nDuring the inspection, PGL’s IMP was reviewed, and third-party emergencies were not addressed\nin those procedures.\nTherefore, PGL’s written procedures required by § 192.12(c) were inadequate. PGL must revise\nits procedures to include all required emergencies and potential possible responses to them in\naccordance with API 1171, Section 10.6.1.\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\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 Peoples Gas Light and Coke Co maintain documentation of the\n\n\n\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\n1-2023-003-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\n\n12023003NOA_Closure Letter_06012023_(21-220263)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJune 1, 2023\nMr. Torrence Hinton\nPresident\nPeoples Gas Light and Coke Co\n200 E Randolph Street\nChicago, Illinois 60601\nCPF 1-2023-003-NOA\nDear Mr. Hinton:\nFrom September 27, 2021 through September 30, 2021, the Illinois Department of Natural\nResources, Office of Oil and Gas Resource Management (IDNR), acting as a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.) inspected Peoples Gas Light and Coke Co’s (PGL) procedures for the\nManlove Underground Gas Storage Facility located in Champaign County, Illinois. As a result of\nthe inspection, PGL was issued a Notice of Amendment on January 12, 2023, which proposed\namendment of your procedures.\nPGL submitted its amended procedures on February 9, 2023. PHMSA issued a Request for Further\nAmendment on March 16, 2023, and PGL submitted its further amended procedures on April 13,\n2023. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in\nthis Notice 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,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":11141}