# LODI GAS STORAGE, LLC — Notice of Amendment

- **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:** Not available
- **summary:** CLOSED notice of amendment citing 192.12(c).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-12023010noa.json
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- **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.

Official case documents:

12023010NOA_Closure Letter_03302023_(21-207392).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023010NOA/12023010NOA_Closure%20Letter_03302023_(21-207392).pdf

12023010NOA_Closure Letter_03302023_(21-207392)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023010NOA/12023010NOA_Closure%20Letter_03302023_(21-207392)_text.pdf

12023010NOA_Notice of Amendment_02232023_(21-207392).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023010NOA/12023010NOA_Notice%20of%20Amendment_02232023_(21-207392).pdf

12023010NOA_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

12023010NOA_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

12023010NOA_Closure Letter_03302023_(21-207392)_text.pdf

CPF 1-2023-010-NOA
Dear Mr. Fournier:
From August 9, 2021, through August 13, 20211
, an inspector from California Geologic Energy
Management Division (CalGEM), acting as an agent for the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)
inspected Lodi Gas Storage LLC’s procedures for the Kirby Hills Storage and Lodi Storage
depleted hydrocarbon Underground Natural Gas Storage Facilities (UNGSF) in Solano County
and San Joaquin County California, respectively. As a result of the inspection, Lodi Gas Storage
LLC was issued a Notice of Amendment on February 23, 2023.
Lodi Gas Storage, LLC submitted its amended procedures on March 24, 2023. My staff reviewed
the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment
have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
P.P.
VIA ELECTRONIC MAIL TO: Mathieu.Fournier@rockpointgs.com
March 30, 2023
Mr. Mathieu Fournier
Manager, Reservoir Engineering
Engineering & Operations
Lodi Gas Storage, LLC
400 - 607 8th Ave SW
Calgary, AB T2P 0A7
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
1 Please note, the Notice of Amendment issued to Lodi Gas Storage, LLC on February 23, 2023 contained an error
in the inspection dates. The correct inspection dates are August 9, 2021, through August 13, 2021.

12023010NOA_Notice of Amendment_02232023_(21-207392)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: Mathieu.Fournier@rockpointgs.com
February 23, 2023
Mr. Mathieu Fournier
Manager, Reservoir Engineering
Engineering & Operations
Lodi Gas Storage, LLC
400 - 607 8th Ave SW
Calgary, AB T2P 0A7
CPF 1-2023-010-NOA
Dear Mr. Fournier:
From August 9, 2021 through August 13, 2022, an inspector from the California Geologic Energy
Management Division (CalGEM), acting as an agent for the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.)
inspected Lodi Gas Storage, LLC’s (LGS) procedures for the Kirby Hills Storage and Lodi Storage
depleted hydrocarbon Underground Natural Gas Storage Facilities (UNGSF) in Solano County
and San Joaquin County California, respectively. LGS has been operating these fields since 2001.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within LGS’s
plans or procedures The items inspected and the inadequacies are described below:
1. 49 CFR § 192.12 Underground natural gas storage facilities.
(a) …
(c) Procedural manuals. Each operator of a UNGSF must prepare
and follow for each facility one or more manuals of written procedures
for conducting operations, maintenance, and emergency preparedness
and response activities under paragraphs (a) and (b) of this section.
Each operator must keep records necessary to administer such
procedures and review and update these manuals at intervals not
exceeding 15 months, but at least once each calendar year. Each
operator must keep the appropriate parts of these manuals accessible
at locations where UNGSF work is being performed. Each operator
must have written procedures in place before commencing operations



or beginning an activity not yet implemented.
LGS written procedures for conducting maintenance and normal operations were inadequate to
ensure safe operation of a pipeline facility. Specifically, LGS’s procedures must include the
provisions of API RP 1171, Section 9 pursuant to § 192.12(b). However, LGS’s manual Risk
Management Plan for the Wells and Reservoirs of the Lodi Underground Gas Storage Project
(RMP) did not include a process to evaluate the mechanical integrity of active wells in accordance
with API RP 1171, Section 9.3.1.
API RP 1171, Section 9.3.1 states, in part, “Active well mechanical integrity evaluations shall
include initial and subsequent evaluations as determined using the risk assessment and the
information derived from the initial evaluation.”
During inspection, PHMSA reviewed the RMP and found RMP, Section 4.3, Mechanical Integrity:
Schedule for Verification and Demonstration did not contain a process to evaluate the mechanical
integrity of active wells.
Therefore, LGS’s written procedures required by § 192.12(c) were inadequate. LGS must revise
its written procedures to include a process to evaluate the mechanical integrity of active wells that
includes initial and subsequent evaluations as determined by the risk assessment.
2. 49 CFR § 192.12 Underground natural gas storage facilities.
(a) …
(c) Procedural manuals. Each operator of a UNGSF must prepare
and follow for each facility one or more manuals of written procedures
for conducting operations, maintenance, and emergency preparedness
and response activities under paragraphs (a) and (b) of this section.
Each operator must keep records necessary to administer such
procedures and review and update these manuals at intervals not
exceeding 15 months, but at least once each calendar year. Each
operator must keep the appropriate parts of these manuals accessible
at locations where UNGSF work is being performed. Each operator
must have written procedures in place before commencing operations
or beginning an activity not yet implemented.
LGS’s written procedures for conducting maintenance and normal operations were inadequate to
ensure safe operation of a pipeline facility. As stated above LGS’s procedures must include the
provisions of API RP 1171, Section 9 pursuant to § 192.12(b). However, LGS’s Operations and
Maintenance Manual, Procedure 7.01, Inspect and Maintain Emergency Valves (Valve Procedure)
did not include a process to maintain, repair, or replace isolation valves in accordance with API
RP 1171, Section 9.3.2.
Section 9.3.2, states in part, “The valves shall be maintained, repaired, or replaced in accordance
with the operator’s valve maintenance program for isolation valves.”
During the inspection, PHMSA reviewed the Valve Procedure. The Valve Procedure failed to



include a process for maintaining, repairing, or replacing wellhead isolation valves. The Valve
Procedure also failed to include a process detailing the prompt remedial action required to correct
any inoperable valves.
Therefore, LGS’s written procedures required by § 192.12(c) were inadequate. LGS must revise
its written procedures to include a process to maintain, repair, or replace isolation valves.
3. 49 CFR § 192.12 Underground natural gas storage facilities.
(a) …
(c) Procedural manuals. Each operator of a UNGSF must prepare
and follow for each facility one or more manuals of written procedures
for conducting operations, maintenance, and emergency preparedness
and response activities under paragraphs (a) and (b) of this section.
Each operator must keep records necessary to administer such
procedures and review and update these manuals at intervals not
exceeding 15 months, but at least once each calendar year. Each
operator must keep the appropriate parts of these manuals accessible
at locations where UNGSF work is being performed. Each operator
must have written procedures in place before commencing operations
or beginning an activity not yet implemented.
LGS’s written procedures for conducting maintenance and normal operations were inadequate to
ensure safe operation of a pipeline facility. Specifically, LGS’s Emergency Response Plan (ERP)
did not include a process for keeping the ERP manuals accessible at locations where UNGSF work
is being performed in accordance with § 192.12(c).
During the inspection, PHMSA reviewed the ERP. The ERP failed to include any requirements
for maintaining the appropriate parts of the manual accessible at locations where UNGSF work is
being performed.
Therefore, LGS’s written procedures required by were inadequate. LGS must revise its written
procedures to include a process for keeping the ERP manuals accessible at locations where
UNGSF work is being performed.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance
Proceedings.
Please refer to this document and note the response options. Be advised that all material you
submit in response to this enforcement action is subject to being made publicly available. If you
believe that any portion of your responsive material qualifies for confidential treatment under 5
U.S.C. § 552(b), along with the complete original document you must provide a second copy of
the document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment under



5 U.S.C. § 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice
and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice
without further notice to you and to issue an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that Lodi Gas Storage, LLC maintain documentation of the safety
improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of
plans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer
to CPF 1-2023-010-NOA and, for each document you submit, please provide a copy in electronic
format whenever possible.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
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