{"operation":"document","citation":"CPF 12023040NOA","title":"AMEREN ILLINOIS COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-06-15","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023040noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023040noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023040noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12023040NOA","body":"Notice of Amendment involving AMEREN ILLINOIS COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2023-06-15 and is reported as closed as of 2023-07-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12023040NOA_Closure Letter_07272023_(22-236004).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023040NOA/12023040NOA_Closure%20Letter_07272023_(22-236004).pdf\n\n12023040NOA_Closure Letter_07272023_(22-236004)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023040NOA/12023040NOA_Closure%20Letter_07272023_(22-236004)_text.pdf\n\n12023040NOA_Notice of Amendment_06152023_(22-236004).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023040NOA/12023040NOA_Notice%20of%20Amendment_06152023_(22-236004).pdf\n\n12023040NOA_Notice of Amendment_06152023_(22-236004)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023040NOA/12023040NOA_Notice%20of%20Amendment_06152023_(22-236004)_text.pdf\n\n12023040NOA_Operator Response to Notice_07132023_(22-236004).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023040NOA/12023040NOA_Operator%20Response%20to%20Notice_07132023_(22-236004).pdf\n\n12023040NOA_Closure Letter_07272023_(22-236004)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJuly 27, 2023\nMr. Patrick Smith\nPresident and Chief Executive Officer\nAmeren Illinois Company\n10 Executive Drive\nCollinsville, Illinois 62234\nCPF-1-2023-040-NOA\nDear Mr. Smith:\nFrom March 21 to 24, 2022, in an on-site inspection, the Illinois Department of Natural Resources,\nOffice of Oil and Gas Resource Management (IDNR), acting as a representative of the Pipeline\nand Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), inspected Ameren Illinois Company’s (AIC) Glasford Storage in Peoria\nCounty, Illinois. As a result of the inspection, AIC was issued a Notice of Amendment on June 15,\n2023, which proposed amendment of your procedures.\nAIC submitted its amended procedures on July 13, 2023. 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,\nP.P.\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n12023040NOA_Notice of Amendment_06152023_(22-236004)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJune 15, 2023\nMr. Leonard P. Singh\nPresident\nAmeren Illinois Company\n10 Executive Drive\nCollinsville, Illinois 62234\nCPF 1-2023-040-NOA\nDear Mr. Singh:\nFrom March 21 to 24, 2022, in an on-site inspection, the Illinois Department of Natural Resources,\nOffice of Oil and Gas Resource Management (IDNR), acting as a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States\nCode (U.S.C.), inspected Ameren Illinois Company’s (AIC) Glasford Storage in Peoria County,\nIllinois.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within AIC’s\nplans or procedures. The items inspected and the inadequacies are described below:\n1. 49 C.F.R. § 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.\n\n\n\nAIC’s written procedures for conducting operations and maintenance activities were inadequate to\nensure safe operation of a pipeline facility. Specifically, AIC’s procedure failed to provide\nsufficient detail to address situations where the testing of the master valve and pipeline isolation\nvalve indicated that the valves failed to isolate the wellhead in accordance with API RP 1171,\nSection 9.3.2 (Section 9.3.2). See § 192.12(b), as incorporated by reference at § 192.7(b)(11).\nSection 9.3.2 states, in part, that “[t]he operator shall test the operation of the master valve and\nwellhead pipeline isolation valve at least annually for proper function and ability to isolate the\nwell. The valves shall be maintained, repaired, or replaced in accordance with the operator’s valve\nmaintenance program for isolation valves.”\nDuring the inspection, the Illinois DNR reviewed AIC’s procedures for wellhead valve testing,\nand noted the procedure did not provide detailed actions to take when a valve fails the isolation\ntest. AIC’s procedure also did not provide detailed actions to repair or replace valves that were\nfound to be defective through annual testing.\nTherefore, AIC’s procedure for wellhead valve testing was inadequate, as it did not include\nprocedures regarding the repair or replacement of valves that were not properly functioning in\naccordance with Section 9.3.2. AIC must revise its procedures to address the inadequacies noted\nabove.\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\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.\n\n\n\nIt is requested (not mandated) that AIC maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Robert Burrough, Director, Eastern Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF 1-\n2023-040-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever 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":8007}