{"operation":"document","citation":"CPF 12023010NOA","title":"LODI GAS STORAGE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-02-23","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023010noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023010noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023010noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12023010NOA","body":"Notice of Amendment involving LODI GAS STORAGE, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2023-02-23 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\n12023010NOA_Closure Letter_03302023_(21-207392).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023010NOA/12023010NOA_Closure%20Letter_03302023_(21-207392).pdf\n\n12023010NOA_Closure Letter_03302023_(21-207392)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023010NOA/12023010NOA_Closure%20Letter_03302023_(21-207392)_text.pdf\n\n12023010NOA_Notice of Amendment_02232023_(21-207392).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023010NOA/12023010NOA_Notice%20of%20Amendment_02232023_(21-207392).pdf\n\n12023010NOA_Notice of Amendment_02232023_(21-207392)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023010NOA/12023010NOA_Notice%20of%20Amendment_02232023_(21-207392)_text.pdf\n\n12023010NOA_Operator Response to Notice_03242023_(21-207392).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023010NOA/12023010NOA_Operator%20Response%20to%20Notice_03242023_(21-207392).pdf\n\n12023010NOA_Closure Letter_03302023_(21-207392)_text.pdf\n\nCPF 1-2023-010-NOA\nDear Mr. Fournier:\nFrom August 9, 2021, through August 13, 20211\n, an inspector from 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 (U.S.C.)\ninspected Lodi Gas Storage LLC’s procedures for the Kirby Hills Storage and Lodi Storage\ndepleted hydrocarbon Underground Natural Gas Storage Facilities (UNGSF) in Solano County\nand San Joaquin County California, respectively. As a result of the inspection, Lodi Gas Storage\nLLC was issued a Notice of Amendment on February 23, 2023.\nLodi Gas Storage, LLC submitted its amended procedures on March 24, 2023. My staff reviewed\nthe amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave 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.\nVIA ELECTRONIC MAIL TO: Mathieu.Fournier@rockpointgs.com\nMarch 30, 2023\nMr. Mathieu Fournier\nManager, Reservoir Engineering\nEngineering & Operations\nLodi Gas Storage, LLC\n400 - 607 8th Ave SW\nCalgary, AB T2P 0A7\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n1 Please note, the Notice of Amendment issued to Lodi Gas Storage, LLC on February 23, 2023 contained an error\nin the inspection dates. The correct inspection dates are August 9, 2021, through August 13, 2021.\n\n12023010NOA_Notice of Amendment_02232023_(21-207392)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: Mathieu.Fournier@rockpointgs.com\nFebruary 23, 2023\nMr. Mathieu Fournier\nManager, Reservoir Engineering\nEngineering & Operations\nLodi Gas Storage, LLC\n400 - 607 8th Ave SW\nCalgary, AB T2P 0A7\nCPF 1-2023-010-NOA\nDear Mr. Fournier:\nFrom August 9, 2021 through August 13, 2022, an inspector 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 (U.S.C.)\ninspected Lodi Gas Storage, LLC’s (LGS) procedures for the Kirby Hills Storage and Lodi Storage\ndepleted hydrocarbon Underground Natural Gas Storage Facilities (UNGSF) in Solano County\nand San Joaquin County California, respectively. LGS has been operating these fields since 2001.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within LGS’s\nplans or procedures The items inspected and the inadequacies are described below:\n1. 49 CFR § 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.\nLGS written procedures for conducting maintenance and normal operations were inadequate to\nensure safe operation of a pipeline facility. Specifically, LGS’s procedures must include the\nprovisions of API RP 1171, Section 9 pursuant to § 192.12(b). However, LGS’s manual Risk\nManagement Plan for the Wells and Reservoirs of the Lodi Underground Gas Storage Project\n(RMP) did not include a process to evaluate the mechanical integrity of active wells in accordance\nwith API RP 1171, Section 9.3.1.\nAPI RP 1171, Section 9.3.1 states, in part, “Active well mechanical integrity evaluations shall\ninclude initial and subsequent evaluations as determined using the risk assessment and the\ninformation derived from the initial evaluation.”\nDuring inspection, PHMSA reviewed the RMP and found RMP, Section 4.3, Mechanical Integrity:\nSchedule for Verification and Demonstration did not contain a process to evaluate the mechanical\nintegrity of active wells.\nTherefore, LGS’s written procedures required by § 192.12(c) were inadequate. LGS must revise\nits written procedures to include a process to evaluate the mechanical integrity of active wells that\nincludes initial and subsequent evaluations as determined by the risk assessment.\n2. 49 CFR § 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.\nLGS’s written procedures for conducting maintenance and normal operations were inadequate to\nensure safe operation of a pipeline facility. As stated above LGS’s procedures must include the\nprovisions of API RP 1171, Section 9 pursuant to § 192.12(b). However, LGS’s Operations and\nMaintenance Manual, Procedure 7.01, Inspect and Maintain Emergency Valves (Valve Procedure)\ndid not include a process to maintain, repair, or replace isolation valves in accordance with API\nRP 1171, Section 9.3.2.\nSection 9.3.2, states in part, “The valves shall be maintained, repaired, or replaced in accordance\nwith the operator’s valve maintenance program for isolation valves.”\nDuring the inspection, PHMSA reviewed the Valve Procedure. The Valve Procedure failed to\n\n\n\ninclude a process for maintaining, repairing, or replacing wellhead isolation valves. The Valve\nProcedure also failed to include a process detailing the prompt remedial action required to correct\nany inoperable valves.\nTherefore, LGS’s written procedures required by § 192.12(c) were inadequate. LGS must revise\nits written procedures to include a process to maintain, repair, or replace isolation valves.\n3. 49 CFR § 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.\nLGS’s written procedures for conducting maintenance and normal operations were inadequate to\nensure safe operation of a pipeline facility. Specifically, LGS’s Emergency Response Plan (ERP)\ndid not include a process for keeping the ERP manuals accessible at locations where UNGSF work\nis being performed in accordance with § 192.12(c).\nDuring the inspection, PHMSA reviewed the ERP. The ERP failed to include any requirements\nfor maintaining the appropriate parts of the manual accessible at locations where UNGSF work is\nbeing performed.\nTherefore, LGS’s written procedures required by were inadequate. LGS must revise its written\nprocedures to include a process for keeping the ERP manuals accessible at locations where\nUNGSF work is being performed.\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 Compliance\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\nthe document 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\n\n\n\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 Lodi Gas Storage, LLC maintain documentation of the safety\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. In correspondence concerning this matter, please refer\nto CPF 1-2023-010-NOA and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":11845}