{"operation":"document","citation":"CPF 12023044WL","title":"AMEREN ILLINOIS COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-06-15","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023044wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023044wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023044wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12023044WL","body":"Warning Letter involving AMEREN ILLINOIS COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(2). The case was opened on 2023-06-15 and is reported as closed as of 2023-06-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12023044WL_Operator Response to Notice_07132023_(22-236004).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023044WL/12023044WL_Operator%20Response%20to%20Notice_07132023_(22-236004).pdf\n\n12023044WL_Warning Letter_06152023_(22-236004).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023044WL/12023044WL_Warning%20Letter_06152023_(22-236004).pdf\n\n12023044WL_Warning Letter_06152023_(22-236004)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023044WL/12023044WL_Warning%20Letter_06152023_(22-236004)_text.pdf\n\n12023044WL_Warning Letter_06152023_(22-236004)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nJune 15, 2023\nMr. Leonard P. Singh\nPresident and Chief Executive Officer\nAmeren Illinois Company\n10 Executive Drive\nCollinsville, Illinois 62234\nCPF 1-2023-044-WL\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, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) ...\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see §192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\n\n\n\nAIC failed to meet the provisions of API RP 1171, Section 8. Specifically, AIC failed to assess the\ninteraction of potential threats and hazards impacting the risk management plan in accordance with\nAPI RP 1171, Section 8.4.2 (Section 8.4.2). See § 192.12(b), as incorporated by reference at §\n192.7(b)(11).\nSection 8.4.2 states, in part, that “[t]he operator should assess potential threat and/or hazard\ninteraction, such as the relationship of the threat of casing damage during well drilling or service\nwork that could exacerbate corrosion processes.”\nDuring the inspection, AIC reported that the interaction of potential threats and hazards impacting\nthe storage facility had not been incorporated into the risk model. Specifically, the interaction of\nthe presence of hydrogen sulfide and the proximity of the nearest dwelling had not been included\nin the risk analysis. The IDNR recommended that AIC address the hydrogen sulfide threat and its\ninteraction with the proximity of nearby dwellings.\nTherefore, Ameren failed to meet the provisions of API RP 1171, Section 8.4.2.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related\nseries of violations. For violation occurring on or after March 21, 2022 and before January 6,\n2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists,\nup to a maximum of $2,391,142 for a related series of violations. For violation occurring on or\nafter May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134\nper violation per day the violation persists, up to a maximum of $2,251,334 for a related series of\nviolations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the\nmaximum penalty may not exceed $222,504 per violation per day the violation persists, up to a\nmaximum of $2,225,034 for a related series of violations. For violation occurring on or after July\n31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the\nmaximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to\nexceed $2,132,679. For violation occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in AIC\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2023-044-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\n\n\n\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":6028}