{"operation":"document","citation":"CPF 12023055NOA","title":"CENTRAL VALLEY GAS STORAGE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-10-18","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023055noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023055noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023055noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12023055NOA","body":"Notice of Amendment involving CENTRAL VALLEY GAS STORAGE, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(1). The case was opened on 2023-10-18 and is reported as closed as of 2024-01-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12023055NOA_Closure Letter_01182024_(22-235017).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023055NOA/12023055NOA_Closure%20Letter_01182024_(22-235017).pdf\n\n12023055NOA_Closure Letter_01182024_(22-235017)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023055NOA/12023055NOA_Closure%20Letter_01182024_(22-235017)_text.pdf\n\n12023055NOA_Notice of Amendment_10182023_(22-235017).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023055NOA/12023055NOA_Notice%20of%20Amendment_10182023_(22-235017).pdf\n\n12023055NOA_Notice of Amendment_10182023_(22-235017)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023055NOA/12023055NOA_Notice%20of%20Amendment_10182023_(22-235017)_text.pdf\n\n12023055NOA_Operator Response to Notice_12202023_(22-235017).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023055NOA/12023055NOA_Operator%20Response%20to%20Notice_12202023_(22-235017).pdf\n\n12023055NOA_Closure Letter_01182024_(22-235017)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJanuary 18, 2024\nMr. Dave Marchese\nChief Executive Officer\nCaliche Development Partners, LLC\n919 Milam Street, Suite 2425\nHouston, TX 77002\nCPF 1-2023-055-NOA\nDear Mr. Marchese:\nFrom February 28, 2022 to March 4, 2022, an inspector from the California Geologic Energy\nManagement Division (CalGEM), acting as an agent for the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Central\nValley Gas Storage, LLC’s procedures for Central Valley Gas Storage depleted hydrocarbon\nUnderground Natural Gas Storage Facility (UNGSF) in Colusa County, California. As a result of the\ninspection, Pacific Gas & Electric Co was issued a Notice of Amendment on October 18, 2023.\nOn November 17, 2023, a letter was sent to request a 30-day extension due to an acquisition of\nownership for Central Valley Gas Storage. On November 21, 2023, an approval of the 30-day\nextension was granted due to the change in ownership.\nCentral Valley Gas Storage, LLC submitted its amended procedures on December 20, 2023. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you for\nyour cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n12023055NOA_Notice of Amendment_10182023_(22-235017)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: jsutton@southernco.com\nOctober 18, 2023\nMr. Jack Sutton\nSenior Vice President Operations Services\nCentral Valley Gas Storage, LLC\n10 Peachtree Place NE\nAtlanta, Georgia 30309\nCPF 1-2023-055-NOA\nDear Mr. Sutton:\nFrom February 28, 2022 to March 4, 2022, an inspector 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 Central Valley Gas Storage, LLC’s (CVGS) procedures for Central Valley Gas Storage\ndepleted hydrocarbon Underground Natural Gas Storage Facility (UNGSF) in Colusa County,\nCalifornia..\nAs a result of the inspection, PHMSA has identified the apparent inadequacy found within CVGS’\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.\nCVGS’ construction procedures required by § 192.12(b)(1) were inadequate. Specifically, CVGS’\nCVGS Integrity and Risk Management Plan (RMP), Section 2.1.1 Eddy-current/Magnetic Flux\nLeakage and Table 6 Annular Vent Pressure Thresholds failed to satisfy API RP 1171 Sections\n\n\n\n11.2.1 (Section 11.2.1) and 6.6.1 (Section 6.6.1).\nSection 11.2.1 states in part “The 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.”\nCorrespondingly, as to those procedures governing the construction, operation, and maintenance\nof the Central Valley Gas Storage UNGS, Section 6.6.1 states, in part, “A well identified as having\ncompromised mechanical integrity shall be evaluated and responsive action implemented within a\ntimeframe and by method(s) determined by the operator and corresponding to the severity of the\nintegrity risk.”\nDuring the inspection, PHMSA reviewed CVGS’ RMP Section 2.1.1 Eddy-current/Magnetic Flux\nLeakage and Table 6 Annular Vent Pressure Thresholds procedures governing certain and found\nthat they lacked responsive procedures under Section 6.6.1. Specifically, those procedures lacked\ntimeframes and relevant descriptions of the integrity evaluation outcomes that might trigger such\nevaluation and responsive actions when compromised mechanical integrity is identified in a well.\nTherefore, CVGS written procedures required by §192.12(b)(1) and API 1171 Sections 11.2.1 and\n6.6.1 were inadequate. CVGS must revise its procedures 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 CVGS maintain documentation of the safety improvement costs\n\n\n\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-\n2023-055-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":8262}