# AMEREN ILLINOIS COMPANY — Warning Letter

- **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:** Not available
- **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.

Official case documents:

12023044WL_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

12023044WL_Warning Letter_06152023_(22-236004).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023044WL/12023044WL_Warning%20Letter_06152023_(22-236004).pdf

12023044WL_Warning Letter_06152023_(22-236004)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023044WL/12023044WL_Warning%20Letter_06152023_(22-236004)_text.pdf

12023044WL_Warning Letter_06152023_(22-236004)_text.pdf

WARNING LETTER
OVERNIGHT EXPRESS DELIVERY
June 15, 2023
Mr. Leonard P. Singh
President and Chief Executive Officer
Ameren Illinois Company
10 Executive Drive
Collinsville, Illinois 62234
CPF 1-2023-044-WL
Dear Mr. Singh:
From March 21 to 24, 2022, in an on-site inspection, the Illinois Department of Natural Resources,
Office of Oil and Gas Resource Management (IDNR), acting as a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States
Code (U.S.C.) inspected Ameren Illinois Company’s (AIC) Glasford Storage in Peoria County,
Illinois.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and
the probable violation is:
1. § 192.12 Underground natural gas storage facilities.
(a) …
(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.
(1) ...
(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an
aquifer reservoir for natural gas storage and was constructed on or
before July 18, 2017, must meet the provisions of API RP 1171
(incorporated by reference, see §192.7), sections 8, 9, 10, and 11, and
paragraph (c) of this section, by January 18, 2018, and must meet all
provisions of paragraph (d) of this section by March 13, 2021.



AIC failed to meet the provisions of API RP 1171, Section 8. Specifically, AIC failed to assess the
interaction of potential threats and hazards impacting the risk management plan in accordance with
API RP 1171, Section 8.4.2 (Section 8.4.2). See § 192.12(b), as incorporated by reference at §
192.7(b)(11).
Section 8.4.2 states, in part, that “[t]he operator should assess potential threat and/or hazard
interaction, such as the relationship of the threat of casing damage during well drilling or service
work that could exacerbate corrosion processes.”
During the inspection, AIC reported that the interaction of potential threats and hazards impacting
the storage facility had not been incorporated into the risk model. Specifically, the interaction of
the presence of hydrogen sulfide and the proximity of the nearest dwelling had not been included
in the risk analysis. The IDNR recommended that AIC address the hydrogen sulfide threat and its
interaction with the proximity of nearby dwellings.
Therefore, Ameren failed to meet the provisions of API RP 1171, Section 8.4.2.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related
series of violations. For violation occurring on or after March 21, 2022 and before January 6,
2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists,
up to a maximum of $2,391,142 for a related series of violations. For violation occurring on or
after May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134
per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of
violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the
maximum penalty may not exceed $222,504 per violation per day the violation persists, up to a
maximum of $2,225,034 for a related series of violations. For violation occurring on or after July
31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per
violation per day the violation persists, up to a maximum of $2,186,465 for a related series of
violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the
maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to
exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November
27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum
penalty not to exceed $2,090,022.
We have reviewed the circumstances and supporting documents involved in this case, and have
decided not to conduct additional enforcement action or penalty assessment proceedings at this
time. We advise you to correct the item identified in this letter. Failure to do so will result in AIC
being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 1-2023-044-WL. 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).
Sincerely,
Robert Burrough
Director, Eastern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
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