{"operation":"document","citation":"CPF 12024009WL","title":"SALTVILLE GAS STORAGE COMPANY, L.L.C. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-02-15","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024009wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024009wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024009wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024009WL","body":"Warning Letter involving SALTVILLE GAS STORAGE COMPANY, L.L.C.. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(1). The case was opened on 2024-02-15 and is reported as closed as of 2024-02-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024009WL_Warning Letter_02152024_(23-264074).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024009WL/12024009WL_Warning%20Letter_02152024_(23-264074).pdf\n\n12024009WL_Warning Letter_02152024_(23-264074)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024009WL/12024009WL_Warning%20Letter_02152024_(23-264074)_text.pdf\n\n12024009WL_Warning Letter_02152024_(23-264074)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nFebruary 15, 2024\nMs. Cynthia Hansen\nPresident and Chief Executive Officer\nSaltville Gas Storage, LLC\n915 North Eldridge Parkway\nHouston, Texas 77079\nCPF 1-2024-009-WL\nDear Ms. Hansen:\nOn August 1, 2023, and August 3, 2023, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected Saltville Gas Storage, LLC’s (Saltville) Early Grove Underground Natural Gas Storage\nFacility in Washington County, Virginia.\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) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed after July\n18, 2017, must meet all provisions of API RP 1171 (incorporated by\nreference, see § 192.7), and paragraphs (c) and (d) of this section, prior\nto commencing operations.\nSaltville failed to meet the provisions of API RP 1171, Section 6. Specifically, Saltville did not\nmaintain records indicating that surface casing was stored, transported, lifted and installed as\nspecified by the manufacturer and in accordance with API 5C1 and API RP 1171, Section 6.3.6\n(Section 6.3.6) and as required to be maintained by API RP 1171, Section 6.11.1 (Section 6.11.1).\n\n\n\nAPI RP 1171, Section 6.3.6 states in part that “Casing shall be stored, transported, lifted and\ninstalled as specified by the manufacturer and in accordance with API 5Cl.” Additionally, Section\n6.11.1 states in part:\nRecords of well completion (as-built), well construction and well work activities\nshall be\nmaintained for the life of the facility. These records shall include, as applicable and\navailable, the items listed below as referenced in each subsection.\n…\n6.3 Well Casing\n…\n- Design evaluations.\nDuring the inspection, Saltville was not able to provide records to verify that surface casing was\nstored, transported, lifted and installed as specified by the manufacturer and in accordance with\nAPI 5C1 for casings used in wells EG-1 and EG-2 that were drilled in 2018.\nTherefore, Saltville failed to meet the provisions of API RP 1171, Section 6.11.1.\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\nSaltville Gas Storage, LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2024-009-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\n\n\n\ncomplete original document you must provide a second copy of the document with the portions\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":5865}