{"operation":"document","citation":"CPF 12023054NOA","title":"WILD GOOSE STORAGE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-09-14","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023054noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023054noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023054noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12023054NOA","body":"Notice of Amendment involving WILD GOOSE STORAGE LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(1). The case was opened on 2023-09-14 and is reported as closed as of 2023-10-31. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12023054NOA_Closure Letter_10312023_(22-235021).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023054NOA/12023054NOA_Closure%20Letter_10312023_(22-235021).pdf\n\n12023054NOA_Closure Letter_10312023_(22-235021)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023054NOA/12023054NOA_Closure%20Letter_10312023_(22-235021)_text.pdf\n\n12023054NOA_Notice of Amendment_09142023_(22-235021).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023054NOA/12023054NOA_Notice%20of%20Amendment_09142023_(22-235021).pdf\n\n12023054NOA_Notice of Amendment_09142023_(22-235021)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023054NOA/12023054NOA_Notice%20of%20Amendment_09142023_(22-235021)_text.pdf\n\n12023054NOA_Operator Response to Notice_10132023_(22-235021).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023054NOA/12023054NOA_Operator%20Response%20to%20Notice_10132023_(22-235021).pdf\n\n12023054NOA_Notice of Amendment_09142023_(22-235021)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: Toby.McKenna@rockpointgs.com\nSeptember 14, 2023\nMr. Tobias McKenna\nChief Executive Officer\nWild Goose Storage, LLC\n607 8th Ave. SW\nSuite 400\nCalgary, AB T2P 0A7\nCPF 1-2023-054-NOA\nDear Mr. McKenna:\nFrom August 15, 2022, through August 19, 2022, inspectors 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 Wild Goose Storage, LLC’s (WGS) procedures for the Wild Goose Storage Field in\nButte County, California.\nAs a result of the inspection, PHMSA has identified the apparent inadequacy found within WGS’\nplans or procedures. The item inspected and the inadequacy is described below:\n1. 49 C.F.R. § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs\n(1) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed after\nJuly 18, 2017, must meet all provisions of API RP 1171 (incorporated\nby reference, see § 192.7), and paragraphs (c) and (d) of this section,\nprior to commencing operations.\nWGS construction procedures required by § 192.12(b)(1) were inadequate. Specifically, WGS’\nWell & Reservoir Integrity Management Plan Manual, Section 5.6 Well Remediation, Revised\nAugust 22, 2022 (Well Remediation Procedure) failed to satisfy API RP 1171, Sections 11.2.1 and\n\n\n\n6.6.1 (Sections 11.2 and 6.6.1).\nSection 11.2.1 requires, in part that “[t]he operator shall develop and follow procedures for the\nconstruction, operation, and maintenance of natural gas storage wells and reservoirs to establish\nand maintain functional integrity.” Correspondingly, as to those procedures governing the\nconstruction, operation, and maintenance of the Wild Goose Storage Field, Section 6.6.1 states\n“[a] well identified as having compromised mechanical integrity shall be evaluated and responsive\naction implemented within a timeframe and by method(s) determined by the operator and\ncorresponding to the severity of the integrity risk.”\nDuring the inspection, PHMSA reviewed WGS’ Well Remediation Procedure, and found that it\nfailed to provide adequate information on how to specifically evaluate and implement response\naction for wells identified as having compromised mechanical integrity. Specifically, the Well\nRemediation Procedures generally just repeats the language of 6.6.1 quoted above, and does not\ndescribe procedures addressing evaluation of a well having compromised mechanical integrity.\nTherefore, WGS’ written procedures governing the construction, operation, and maintenance of the\nWild Goose Storage Field to establish and maintain functional integrity required by §192.12(b)(1)\nwere inadequate. WGS must revise its process to address the deficiency outlined above.\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.\nIt is requested (not mandated) that Wild Goose Storage, LLC maintain documentation of the safety\n\n\n\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 1-2023-054-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\n\n12023054NOA_Closure Letter_10312023_(22-235021)_text.pdf\n\nVIA ELECTRONIC MAIL TO: Toby.McKenna@rockpointgs.com\nOctober 31, 2023\nMr. Tobias McKenna\nChief Executive Officer\nWild Goose Storage, LLC\n607 8th Ave. SW\nSuite 400\nCalgary, AB T2P 0A7\nCPF 1-2023-054-NOA\nDear Mr. McKenna:\nFrom August 15, 2022, through August 19, 2022, inspectors 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 Wild Goose Storage, LLC’s (WGS) procedures for the Wild Goose Storage Field in\nButte County, California. As a result of the inspection, WGS was issued a Notice of Amendment\non September 14, 2023 requiring WGS to amend certain aspects of its procedures.\nWGS submitted its amended procedures on October 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,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":7961}