{"operation":"document","citation":"CPF 12024002NOA","title":"EGYPTIAN GAS STORAGE CORP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-01-18","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c), 192.12(d)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024002noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024002noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024002noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024002NOA","body":"Notice of Amendment involving EGYPTIAN GAS STORAGE CORP. PHMSA's enforcement data identifies the cited regulations as 192.12(c),  192.12(d)(4). The case was opened on 2024-01-18 and is reported as closed as of 2025-01-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024002NOA_Closure Letter_01072025_(22-236177).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024002NOA/12024002NOA_Closure%20Letter_01072025_(22-236177).pdf\n\n12024002NOA_Closure Letter_01072025_(22-236177)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024002NOA/12024002NOA_Closure%20Letter_01072025_(22-236177)_text.pdf\n\n12024002NOA_Notice of Amendment_01182024_(22-236177).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024002NOA/12024002NOA_Notice%20of%20Amendment_01182024_(22-236177).pdf\n\n12024002NOA_Notice of Amendment_01182024_(22-236177)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024002NOA/12024002NOA_Notice%20of%20Amendment_01182024_(22-236177)_text.pdf\n\n12024002NOA_Operator Response to Notice_03132024_(22-236177).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024002NOA/12024002NOA_Operator%20Response%20to%20Notice_03132024_(22-236177).pdf\n\n12024002NOA_Closure Letter_01072025_(22-236177)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJanuary 7, 2025\nMr. Charles Robinson\nPresident\nEgyptian Gas Storage Corp.\n1410 North Cullen Avenue\nEvansville, IN 47715\nCPF 1-2024-002-NOA\nDear Mr. Robinson:\nFrom October 3rd to 6th, 2022, inspectors from the Illinois Department of Natural Resources\n(ILDNR), acting as an agent for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of Title 49 United States Code (U.S.C.), inspected Egyptian\nGas Storage Corporation’s (EGSC) procedures for the Mills Gas Storage facility in Gallatin\nCounty, Illinois.\nOn January 18, 2024, based on the results of the inspection, PHMSA issued a Notice of\nAmendment to EGSC, with a response required within 30 days of receipt of the notice.\nPursuant to a request by EGSC for a time extension to file its response to the Notice of\nAmendment, PHMSA granted a 30-day extension. Egyptian Gas Storage submitted its amended\nprocedures on March 13, 2024. My staff reviewed the amended procedures, and determined that\nthe inadequacies outlined in the Notice of Amendment had not been completely addressed.\nOn April 30, 2024, PHMSA issued a Request for Further Amendment for the five items noted in\nNotice of Amendment.\nOn July 12, 2024, inspectors from the ILDNR conducted a followup inspection with EGSC to\ndiscuss and evaluate the amended plans and procedures. Egyptian Gas Storage provided copies of\nmost of the further amended plans and procedures to the ILDNR during the inspection, and some\npost-inspection. My staff reviewed the procedures, and also confirmed that the documents\nprovided to the ILDNR were attached to the inspection record, commencing on July 15, 2024, and\ncompleting on October 17, 2024, and were evaluated as satisfactory by the ILDNR.\n\n\n\nThis letter is to inform you that it appears that the inadequacies outlined in the Notice of\nAmendment and the Request for Further Amendment have been corrected. No further action is\nnecessary, and this case is now closed. Thank you for your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n12024002NOA_Notice of Amendment_01182024_(22-236177)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJanuary 18, 2024\nMr. Charles Robinson\nPresident\nEgyptian Gas Storage Corp.\n1410 North Cullen Avenue\nEvansville, IN 47715\nCPF 1-2024-002-NOA\nDear Mr. Robinson:\nFrom October 3rd to 6th\n, 2022, inspectors from the Illinois Department of Natural Resources\n(ILDNR), acting as an agent for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of Title 49 United States Code (U.S.C.), inspected Egyptian\nGas Storage Corporation’s (EGSC) procedures for the Egyptian Gas Storage Facility (Egyptian)\nin Gallatin County, Illinois.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nEGSC’s plans 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\nEGSC’s written procedures for conducting emergency preparedness and response activities were\ninadequate to ensure safe operation of a pipeline facility. Specifically, EGSC’s Operations,\nMaintenance, and Emergency Manual, Section 9 – Emergency Plan (Emergency Plan) failed to\naddress accidental releases, equipment failures and third-party emergencies pursuant to API RP\n1171, Section 10.6.1. API RP 1171 is incorporated by reference in § 192.7(b)(11) and is applicable\nto Egyptian’s facility under § 192.12.\nAPI RP 1171, Section 10.6.1 requires, in part, that \"For site security and safety, the operator shall\ndevelop and implement a structured emergency preparedness/response plan in order to address\naccidental releases, equipment failures, natural disasters, and third-party emergencies.\"\nDuring the inspection, EGSC’s Emergency Plan was reviewed and determined to not address\naccidental releases, equipment failures, or third-party emergencies.\nTherefore, EGSC’s Emergency Plan was inadequate. EGSC must revise its written emergency\nprocedures to address these aspects discussed above.\n2. 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.\nEGSC’s manual of written procedures for emergency preparedness and responses activities were\ninadequate to assure safe operation of a pipeline facility. Specifically, EGSC did not have a written\nblowout contingency plan (BCP) in place pursuant to API RP 1171, Section 10.6.3.\nAPI 1171, Section 10.6.3 requires in part that \"The operator shall have a blowout contingency plan\nin place.\"\nDuring the inspection, EGSC’s BCP was requested, and EGSC was unable to provide a written\nBCP.\nTherefore, EGSC failed to meet the requirements of § 192.12(c). EGSC must revise its emergency\npreparedness and responses procedures to include a written BCP.\n3. 49 C.F.R. § 192.12 Underground natural gas storage facilities.\n(a) …\n\n\n\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.\nEGSC’s written procedures for conducting operations and maintenance activities were inadequate\nto ensure safe operation of a pipeline facility. Specifically, EGSC’s Operations, Maintenance, and\nEmergency Manual, Section 9 – Integrity Demonstration, Verification and Monitoring Practices\n(Section 9 Procedures) failed to include procedures describing how to annually test the operation\nof the master valve and wellhead pipeline isolation valve for proper function and ability to isolate\nthe well.\nAPI 1171, Section 9.3.2 requires in part that \"The operator shall test the operation of the master\nvalve and wellhead pipeline isolation valve at least annually for proper function and ability to\nisolate the well.\"\nDuring the inspection, EGSC’s Section 9 Procedures were reviewed and found to not include a\nprocess for annually testing the operation of the master valve and wellhead pipeline isolation valve.\nThere was no effective date included on the procedures presented at the time of the inspection.\nAfter the inspection updated procedures were submitted on 12/01/2022. However, these revised\nprocedures also did not include requirements for annually testing the operation of the master valve\nand wellhead pipeline isolation valve, and also lacked an effective date for the procedure.\nTherefore, EGSC’s written procedures required by § 192.12(c) were inadequate. EGSC must\nrevise its written procedures to include a process to maintain, repair, or replace isolation valves.\n4. 49 C.F.R. § 192.12 Underground natural gas storage facilities.\n(a) …\n(d) Integrity management program\n(1) …\n(4) Integrity management procedures and recordkeeping. Each\nUNGSF operator must establish and follow written procedures to carry\nout its integrity management program under API RP 1171\n(incorporated by reference, see § 192.7), section 8 (“Risk Management\nfor Gas Storage Operations”), and this paragraph (d). The operator\nmust also maintain, for the useful life of the UNGSF, records that\ndemonstrate compliance with the requirements of this paragraph (d).\nThis includes records developed and used in support of any\nidentification, calculation, amendment, modification, justification,\n\n\n\ndeviation, and determination made, and any action taken to implement\nand evaluate any integrity management program element.\nEGSC’s written procedures for carrying out its integrity management program were inadequate to\nensure safe operation of a pipeline facility. Specifically, EGSC’s Risk Management for Gas\nStorage Operations, Section 8.6 – Preventive and Mitigative Measures failed to include a process\nto manage risks based on their risk ranking methodology.\nAPI 1171, Section 8.6.2 requires in part that \"The operator shall develop P&M measures to manage\nrisks.”\nDuring the inspection, it was determined that EGSC ranks each well from low to high based on\neight criteria, but the procedure did not state if and how these safety concerns are to be addressed\nwith preventative & mitigative measures based on this ranking. Further, Table 4 in Section 8.6.1\nof EGSC’s Risk Management for Gas Storage Operations generically list preventative &\nmitigative measures from API RP 1171, but EGSC does not specify which ones will be used or\napplied to EGSC’s wells or facility to manage risks.\nTherefore, EGSC’s written procedures required by § 192.12(d)(4) were inadequate. EGSC must\nrevise its written procedures to include a process to manage risk based on this ranking and to\ndevelop preventative & mitigative measures to apply to the wells to address such risk.\n5. 49 C.F.R. § 192.12 Underground natural gas storage facilities.\n(a) …\n(d) Integrity management program\n(1) …\n(4) Integrity management procedures and recordkeeping. Each\nUNGSF operator must establish and follow written procedures to carry\nout its integrity management program under API RP 1171\n(incorporated by reference, see § 192.7), section 8 (“Risk Management\nfor Gas Storage Operations”), and this paragraph (d). The operator\nmust also maintain, for the useful life of the UNGSF, records that\ndemonstrate compliance with the requirements of this paragraph (d).\nThis includes records developed and used in support of any\nidentification, calculation, amendment, modification, justification,\ndeviation, and determination made, and any action taken to implement\nand evaluate any integrity management program element.\nEGSC’s written procedures to carry out its integrity management program were inadequate to\nensure safe operation of a pipeline facility. Specifically, EGSC did not have a procedure that\naddressed utilizing the risk assessment process to determine frequency requirements for the\nmechanical integrity evaluation of each active well, including each third-party well that penetrates\nthe storage reservoir and buffer zone or areas influenced by storage operations.\nAPI 1171, Section 9.3.1 requires, in part, that \"The operator shall evaluate the mechanical integrity\nof each active well, including each third-party well, that penetrates the storage reservoir and buffer\n\n\n\nzone or areas influenced by storage operations.... Active well mechanical integrity evaluations\nshall include initial and subsequent evaluations as determined using the risk assessment and the\ninformation derived from the initial evaluation.\"\nDuring the inspection, EGSC did not have a procedure that addressed utilizing the risk assessment\nprocess to determine frequency requirements for the mechanical integrity evaluation of each active\nwell, including each third-party well that penetrates the storage reservoir and buffer zone or areas\ninfluenced by storage operations. EGSC also did not have a procedure that addressed the process\nto determine which methods are to be used for initial and subsequent mechanical integrity\nevaluations.\nTherefore, EGSC’s written integrity management procedures were inadequate pursuant to\n§ 192.12(d)(4). EGSC must amend its procedures to include a risk assessment process for\ndetermining which methods are to be used for the initial and subsequent mechanical integrity\nevaluations of each well as required by API 1171 Section 9.3.1. The procedures must also be\namended to include a process to determine the frequency requirements for integrity demonstration,\nverification, and monitoring tasks or activities.\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 EGSC 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\n\n\n\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF 1-\n2024-002-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":17109}